Navarro v. Block (May 11, 2001)
* court: Ninth Circuit
* public agency: Los Angeles Deputy Sheriffs
* plaintiffs' job classes: deputy sheriffs
* plaintiff's attorneys: Yagman & Yagman
* trial court's decision: in favor of plaintiffs
* Ninth Circuit's decision: in favor of plaintiffs
* issue area: false arrest, Warrant, Section 1983
Navarro Facts
* A group of Los Angeles deputies sued the Los Angeles County Board of
Supervisors under section 1983. The
deputies claimed that the Board violated the constitutional rights of
the deputies by refusing in bad faith to indemnify deputies against
punitive damage awards.
* The county moved to dismiss the case on the ground that the Board, even
if acted in bad faith, deserved qualified immunity.
* The district court denied the motion; the county filed an interlocutory
appeal.
* The Ninth Circuit affirmed the district court.
Navarro
Analysis
* The Board argued that it was entitled to qualified immunity even if it
acted in bad faith.
* The Ninth Circuit said no, relying on three earlier cases.
* In the 1994 Trevino case (Trevino I), plaintiffs
sued on the same issue as the Navarro plaintiffs.
The Los Angeles City Council argued that it possessed absolute
immunity as to its decisions to indemnify police officers from
punitive damage awards. In
Trevino I, the Ninth Circuit rejected this argument.
* In the 1996 Trevino case (Trevino II), the
Ninth Circuit held that local legislators were entitled to qualified
immunity in deciding whether to indemnify for punitive damages, as
long as they exercised their discretion in good faith.
* In the 2000 Cunningham case, the Ninth Circuit held
that, if local legislators acted in bad faith in exercising their
discretion as to punitive damages awards, then they would not be
entitled to qualified immunity.
*
The bottom line is that plaintiffs are now able to start discovery and
to try to find facts showing bad faith, but it will be an uphill
battle.
