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$1.8 Million Jury Award for San Diego Jail Overdose Death

On April 25, 2024, a federal jury in Southern California awarded $1.8 million to the Estate of a detainee who died of a methamphetamine overdose while incarcerated at the San Diego Central Jail. The verdict was preceded by a finding that two jail nurses intentionally denied Ronnie Sandoval needed medical care, causing his death.

When arrested for methamphetamine possession on February 22, 2014, Sandoval, 46, was found with only a small amount of the drug—because he had secretly ingested a large amount just before his arrest. During booking, San Diego County Sheriff’s Office (SDSO) deputies noticed he was sweating, disoriented, and lethargic. Sandoval tried to explain away the symptoms by claiming to be diabetic. But a nurse checked his blood sugar, which tested as normal. An hour later, still showing the same symptoms, Sandoval was taken to the jail medical station, where nurse Romeo De Guzman performed another quick blood sugar test and had him placed in a medical observation cell, one which was also used by security.

Sandoval went unobserved for the next eight hours. He was then found suffering a seizure. Nurses Dana Harris and Maria Llamado were summoned. Llamado told an EMT-trained SDSO deputy to call for EMTs, but he refused. Eventually, she called for them herself. But when they arrived, they refused to transport Sandoval—because he was still seizing—and called for paramedics. By the time they arrived, 47 minutes had elapsed since Sandoval was discovered seizing. While he was being lifted onto a stretcher, his heart stopped; he died within minutes.

With the assistance of San Diego attorneys Danielle Renee Pena of PHG Law Group, Vincent Renda of Pinnacle Legal and Christopher S. Morris of the Morris Law Firm, Sandoval’s Estate filed a federal civil rights lawsuit against the county and the nurses in federal court for the Southern District of California. Defendants filed a boilerplate motion for summary judgment, which U.S. District Judge Roger T. Benitez granted. The Estate appealed.

As PLN reported, the U.S. Court of Appeals for the Ninth Circuit reversed that ruling and remanded the case, holding that the boilerplate motion was meritless and that the district court’s grant of it was an abuse of discretion; the trial court had also applied an incorrect standard, the appellate Court said. [See: PLN, June 2021, p.58.] On remand, San Diego attorney Joseph M. McMullen joined Plaintiffs’ team, and Morris dropped out to become a state court judge.

Defendants included three very sympathetic nurses, who insisted that Sandoval had not told them that he had ingested any drugs. That failure made Sandoval fully liable for his own death, they argued; moreover, the amount of methamphetamine involved—“a lot of meth, more meth than anyone has ever taken in the history of meth,” a County attorney declared—would have killed him no matter what the nurses did, a claim supported by a toxicologist’s testimony. But an Emergency Room doctor testified that prompt intervention could have saved Sandoval’s life. The Estate’s attorneys also noted that the doctor treats drug overdose patients every day, whereas the toxicologist had treated only five overdose patients in her entire career.

With that, the jury found that De Guzman and Harris intentionally denied Sandoval needed medical care causing his death. The Estate was awarded $850,000 for Sandoval’s pain and suffering and $2,750,000 for his death. However, the jury found that Sandoval was partially liable, so only 50% of those amounts were awarded to the Estate. The other nurses and the County were not found liable. See: Est. of Sandoval v. Cty. of San Diego, USDC (S.D. Cal.), Case No. 3:16-cv-01004. Defendants moved for Judgment as a Matter of Law, but that motion was denied on August 29, 2024. See: Sandoval v. Cty. of San Diego, 2024 U.S. Dist. LEXIS 155838 (S.D. Cal.).

In Benitez, the Estate’s attorneys faced a judge who showed little sympathy for drug use; in February 2023, he had a drug defendant’s 13-year-old daughter handcuffed during her father’s sentencing to make the point that she should avoid following in his footsteps. For that, Benitez was reprimanded by the Ninth Circuit’s Judicial Council on May 1, 2024. See: In re Complaint Judicial Misconduct, USCA (9th Cir), Nos. 23-90037, 23-90041.  

Additional source: San Diego Union-Tribune

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