Federal judge declines to dismiss latest jail-death case against San Diego County

A federal judge in San Diego has refused to dismiss a lawsuit against the county, its sheriff and a host of jail medical providers who were involved in the 2022 death of a man who died in custody.

The ruling Thursday by U.S. District Judge Dana M. Sabraw means San Diego County will face another wrongful-death liability trial – or reach a pretrial settlement like those that have cost taxpayers tens of millions of dollars in recent years.

The latest legal dispute involves the death three years ago of 22-year-old William Hayden Schuck, who died a few days after being booked into custody at the sheriff’s Central Jail.

The judge said there was ample evidence of possible negligence and other lapses to proceed to trial.

Sabraw, who is married to District Attorney Summer Stephan, also noted that defendants have not made significant changes to training and other sheriff’s policies even though 185 people died in San Diego County jails between 2006 and 2020.

“While not all in-custody deaths necessarily arise from unconstitutional conduct, this evidence suggests that the county has been passive in the aftermath of all deaths, resulting from deliberate indifference, mere negligence, or otherwise,” notes the 58-page ruling, which was first reported by Courthouse News Service.

“A reasonable jury could find that this practice constitutes deliberate indifference,” Sabraw wrote.

Sabrina Schuck, the deceased man’s mother, said it was heartbreaking to read the judge’s ruling, but she also felt vindicated by the order.

“We are deeply grateful for his thorough investigation and review of the facts,” she said in a statement Monday. “We are once again devastated to continue to learn just how much Hayden suffered in his last days and see how clearly preventable his death was.

“After nearly four years, our entire family hopes and prays that justice is finally near for Hayden,” she added.

Lawyers for Schuck said they were pleased with the court’s interpretation of the case.

“This ruling clears the way for a jury to hear what happened,” attorney Timothy Scott said by email. “We look forward to trial in November and to justice for Hayden.”

Neither San Diego County nor Sheriff Kelly A. Martinez agreed to comment on the decision, the latest in a series of legal setbacks that have resulted from in-custody deaths.

The families of people who have died in San Diego County jails have collected tens of millions of dollars in legal judgments and jury awards in recent years.

County supervisors voted 4-1 just last week to expand the jurisdiction of the Citizens’ Law Enforcement Review Board, or CLERB, to include oversight of the jail’s medical staff to promote better care of people in custody.

The decision from Sabraw also comes less than two months after a federal magistrate judge in the same case described the county’s handling of video evidence in the Schuck case “shocking in the height of negligence.”

Even though the Sheriff’s Office has a written policy requiring surveillance video to be preserved for at least two years, deputies allowed dozens of hours of footage to be erased.

The deletion of 57 hours of relevant video came after county attorneys received two notices requesting that officials retain all records and video related to Schuck’s incarceration and death.

One sheriff’s official said in a deposition that “there probably isn’t a single deputy in the department” who is aware of the video-retention policy. Instead, the video is routinely overridden when the recording system reaches its storage threshold.

According to lawyers representing Schuck’s family, the missing video came from a camera aimed at a hallway outside a holding cell where Schuck was detained for approximately five days.

The video evidence could have captured whether and when deputies performed required welfare checks on Schuck, or whether and when jail medical staff entered the cell.

Both issues are key elements of the wrongful-death claims the family filed in 2023 against the county and Correctional Healthcare Partners, one of the county’s contracted medical providers.

Schuck was involved in a rollover vehicle crash on March 10, 2022, court records show. He was arrested on suspicion of driving under the influence of a controlled substance and possession of firearms but a nurse at Central Jail declined him for booking and instead directed him to a local hospital.

“Schuck’s transporting officer described his behavior as ‘erratic’ and ‘consistent with someone under the influence of methamphetamines,’” the Sabraw ruling states.

The suspect was transported to the hospital but declined treatment, and was returned to jail for booking.

Schuck spent five days in custody but received limited medical attention. One deputy advised a colleague that “this man needs to go to medical” but Schuck nonetheless was not properly treated, court records show.

On March 16, he was found “not responsive” and declared deceased a short time later.

“Schuck’s autopsy revealed that he died from complications relating to cocaine and (ecstasy) toxicity,” the judge’s ruling noted. “Following Schuck’s death, the jail staff involved received no feedback, guidance, training, or discipline by the county.”

Sabraw also cited a 2022 state audit – released six weeks before Schuck died in custody – that showed San Diego County jails had one of the highest death rates among California jails, with 185 deaths between 2006 and 2020.

Even so, testimony in the Schuck case showed that the Sheriff’s Office has failed to learn from past errors and continues to experience deaths that might otherwise be prevented.

“This systemic lack of reflection after the death of a detainee is alarming,” he wrote.

Sabraw said a reasonable jury could find the county guilty of deliberate indifference, rendering officials responsible for civil damages.

Jurors “could also conclude that the county’s unwillingness to investigate the root causes of in-custody deaths and to institute dialogue with its employees on how to be more proactive caused Schuck’s death,” the judge added.

The ruling paves the way for an out-of-court settlement or a trial, although no trial date has yet been scheduled.