San Diego County, California, et al. v. Ana Sandoval, et al.
DueProcess Punishment CriminalProcedure
Whether a pretrial detainee must show subjective awareness of medical needs or only objective unreasonableness
question presented is: Under the Fourteenth Amendment, must a pretrial detainee alleging deliberate indifference to medical needs prove that the defendant was subjectively aware of his or her medical needs? Or is it sufficient that the defendant’s actions were objectively unreasonable? 2. The events at issue in this action occurred in 2014. At the time, the Ninth Circuit applied a subjective deliberate indifference test. In 2018, the Ninth Circuit changed course, and adopted its objective deliberate indifference test. The second question presented is: In determining whether a right is “clearly established” for purposes of qualified immunity, must courts address the elements of the claim that existed at the time of the events at issue? Or may they ignore elements based on subsequent changes to the law, as the majority held below?