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Harrison v. Sparks

Citation: 342 F. App'x 334Docket: No. 07-16798

Court: Court of Appeals for the Ninth Circuit; August 14, 2009; Federal Appellate Court

Narrative Opinion Summary

In this case, a California state prisoner appealed a district court's summary judgment favoring the Kern County Sheriff's Department and its officials under 42 U.S.C. § 1983. The appellate court reviewed the case de novo and affirmed the lower court's decision, concluding that the claims against the Supervisory Defendants were insufficient. The court found no constitutional violations in the policies or training provided by the Supervisory Defendants, referencing Monell v. Department of Social Services. It also held that the protocols for using the R.E.A.C.T. belt, which were validated by the manufacturer, did not demonstrate deliberate indifference as outlined in City of Canton v. Harris. Furthermore, the court determined that the prisoner's due process rights were not violated during court proceedings since the use of the R.E.A.C.T. belt was mandated by the trial judge. The appellate court also clarified that it lacked jurisdiction over a separate 2007 judgment favoring a deputy sheriff, as the appeal only addressed the 2002 judgment. The court denied the motion for clarification of the record and affirmed that the decision is not to be published as precedent except under specific Ninth Circuit rules.

Legal Issues Addressed

Due Process Rights in Court Appearances

Application: Harrison's due process rights were held not to be violated during his court appearance while wearing the R.E.A.C.T. belt, as its use was mandated by the trial judge.

Reasoning: Additionally, Harrison's due process rights were not infringed upon during his court appearance while wearing the R.E.A.C.T. belt, as the trial judge mandated its continued use.

Jurisdiction Over Appeals

Application: The court lacked jurisdiction over the 2007 judgment regarding Deputy Waidelich as Harrison's Notice of Appeal only addressed the 2002 judgment.

Reasoning: The court affirms the district court's summary judgment in favor of the Supervisory Defendants but notes that it lacks jurisdiction over the 2007 judgment favoring Deputy Waidelich, as Harrison's Notice of Appeal only addresses the 2002 judgment.

Summary Judgment under 42 U.S.C. § 1983

Application: The court upheld the district court's summary judgment in favor of the Supervisory Defendants, finding no constitutional violation under 42 U.S.C. § 1983.

Reasoning: Harrison contends that the district court erred in granting summary judgment for the Supervisory Defendants, but the court reviews this de novo and can affirm based on any record-supported basis.

Supervisory Liability and Monell Claims

Application: The court found Harrison's claims regarding the Supervisory Defendants' official policies unpersuasive, relying on Monell v. Department of Social Services.

Reasoning: Harrison's claims regarding the Supervisory Defendants' official policies are deemed unconvincing, referencing Monell v. Department of Social Services.

Training and Deliberate Indifference

Application: The court determined that the training on the R.E.A.C.T. belt protocol did not amount to deliberate indifference, as the protocol was validated by its manufacturer.

Reasoning: The court finds that the R.E.A.C.T. belt activation protocol used by deputies was validated by its manufacturer, and training on this protocol does not constitute deliberate indifference, as established in City of Canton v. Harris.