Navarro v. Santa Cruz, County of

CourtDistrict Court, D. Arizona
DecidedAugust 29, 2025
Docket4:24-cv-00353
StatusUnknown

This text of Navarro v. Santa Cruz, County of (Navarro v. Santa Cruz, County of) is published on Counsel Stack Legal Research, covering District Court, D. Arizona primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Navarro v. Santa Cruz, County of, (D. Ariz. 2025).

Opinion

1 WO 2 3 4 5 6 IN THE UNITED STATES DISTRICT COURT 7 FOR THE DISTRICT OF ARIZONA 8 9 10 Maria Del Carmen Hernandez, et al., No. CV-24-00353-TUC-SHR 11 12 Plaintiffs, ORDER 13 14 v. 15 16 County of Santa Cruz, et al., 17 18 Defendants. 19 20 21 Pending before the Court is Defendant’s Partial Motion to Dismiss for Failure to 22 State a Claim (Doc. 32). The Motion to Dismiss is fully briefed. (Doc. 20; Doc. 36; Doc 23 37.) For the reasons set forth below, the Motion to Dismiss is denied in part and granted 24 in part, and Plaintiffs are given leave to amend. 25 I. Factual Background1 26 This dispute arises from an incident in which Defendant, Augustine Huerta, a 27 1 For the purposes of resolving this Motion, the Court construes the facts in the light 28 most favorable to Plaintiff. Facts herein are derived entirely from those in the First Amended Complaint (FAC). (See Doc. 20.) 1 Commander with the Santa Cruz County Sheriff’s Department (“Defendant County”), 2 fatally shot David Hernandez (the “decedent”). (Doc. 20 ¶¶ 1–2.) The shooting followed 3 Defendant Huerta’s brief attempt to make verbal contact with the decedent outside his 4 residence as he appeared to be gardening. (Doc. 20 ¶¶ 26–40.) 5 Despite Defendant Huerta’s attempts to speak with the decedent, the decedent 6 “continued walking away.” (Id. ¶ 31.) In an interview, Defendant Huerta claimed he had 7 observed knives in the decedent’s hands. (Id. ¶ 34.) At that time, Defendant Huerta 8 contemplated using his taser to subdue the decedent. (Id. ¶ 36.) Because Defendant Huerta 9 thought the taser might miss, he decided to use his gun. (Id.) 10 Then, Defendant Huerta repositioned himself so the home across the street would 11 not be in the line of fire of a potential bullet. (Id. ¶¶ 37–38.) After Defendant Huerta 12 repositioned himself, the decedent “raised his arms with the knives.” (Id. ¶ 39.) 13 “Defendant Huerta fired five rounds,” striking the decedent each time in the back. (Id. 14 ¶¶ 2, 40.) The decedent fell to the ground, still alive and bleeding. (Id. ¶ 41.) 15 Defendant Huerta failed to provide medical aid to the decedent, and prevented, 16 delayed, and interfered with other individuals—including the decedent’s brother, Christian 17 A. Hernandez and a nurse—who sought to render medical aid after the shooting. (Id. 18 ¶¶ 44–48, 114.) After producing her credentials, “[t]he nurse was eventually permitted to 19 approach [the decedent].” (Id. ¶ 49.) The decedent died because of his injuries. (Id. ¶ 2.) 20 II. Procedural Background 21 Plaintiffs filed their initial complaint on July 17, 2024. (Doc. 1.) At the time of 22 filing, Plaintiffs were Maria Del Carmen Hernandez, decedent’s mother, in her individual 23 capacity and on behalf of the decedent’s statutory beneficiaries, and Christian Hernandez 24 in his capacity as personal representative of David Hernandez (“Decedent’s Estate”). (Doc. 25 1.) 26 Maria died on August 26, 2024. (Doc. 25 at 2.) Therefore, this Court granted 27 Plaintiff’s Motion for Substitution of Real Party of Interest, substituting Christian A. 28 Hernandez as the real party in interest in place of Plaintiff Maria Del Carmen Hernandez. 1 (Doc. 27.) As a result, Christian brings this action, in his capacity as personal 2 representative, on behalf of (1) the Decedent’s Estate, (2) the Estate of Ramon Bernal 3 Hernandez (“Father’s Estate”), and (3) the Estate of Maria Del Carmen Hernandez 4 (“Mother’s Estate”). (Doc. 20.) 5 Plaintiffs filed a First Amended Complaint (FAC) on October 14, 2024. (Doc. 20.) 6 Plaintiffs’ FAC asserts the following claims: Assault/Battery resulting in Wrongful Death 7 (against Defendant Huerta and vicarious liability against Defendant Hathaway); Negligent 8 Supervision and Training Resulting in Wrongful Death (against Defendants County and 9 Hathaway); Fourth Amendment Unreasonable Use of Force (against Defendant Huerta); 10 Supervisor Liability (against Defendant County); Fourteenth Amendment Loss of Familial 11 Association (against Defendants Huerta and County); Gross Negligence resulting in 12 Wrongful Death (against all Defendants). (Id.) 13 Defendants have filed a partial motion to dismiss (Doc. 32), which has been fully 14 briefed. (Doc. 36; Doc. 37.) 15 III. Legal Standard 16 A. Motion to Dismiss Standard 17 The pleading standard for a motion to dismiss is governed by Rule 8(a) of the 18 Federal Rules of Civil Procedure, which requires “a complaint to contain ‘a short and plain 19 statement of the claim showing . . . the pleader is entitled to relief.’” Glazer Cap. Mgmt., 20 L.P. v. Forescout Techs., Inc., 63 F.4th 747, 763 (9th Cir. 2023) (quoting Fed. R. Civ. P. 21 8(a)(2)). “Dismissal [under Rule 12(b)(6)] can be based on the lack of a cognizable legal 22 theory or the absence of sufficient facts alleged under a cognizable legal theory.” Balistreri 23 v. Pacifica Police Dep’t, 901 F.2d 696, 699 (9th Cir. 1988). A complaint must “contain 24 sufficient factual matter, accepted as true, to ‘state a claim to relief that is plausible on its 25 face.’” Glazer Cap. Mgmt., 63 F.4th at 763 (quoting Ashcroft v. Iqbal, 556 U.S. 662, 678 26 (2009)). While “[a]ll allegations of material fact are taken as true and construed in the light 27 most favorable to the nonmoving party,” Silvas v. E*Trade Mortg. Corp., 514 F.3d 1001, 28 1003 (9th Cir. 2008), “[t]hreadbare recitals of the elements of a cause of action, supported 1 by mere conclusory statements, do not suffice,” Plaskett v. Wormuth, 18 F.4th 1072, 1083 2 (9th Cir. 2021) (quoting Iqbal, 556 U.S. at 678). 3 B. Leave to Amend Standard 4 Under Federal Rule of Civil Procedure 15(a)(2), leave to amend should be “freely 5 given.” However, leave to amend should not be granted when amendment would be futile. 6 Ebner v. Fresh, Inc., 838 F.3d 958, 968 (9th Cir. 2016). The Court can recognize 7 amendment would be futile if the pleading could not possibly be cured by the allegation of 8 other facts. Doe v. United States, 58 F.3d 494, 497 (9th Cir. 1995). 9 IV. Analysis 10 A. Standing to Bring Wrongful Death Claims: Survival Actions 11 Defendants allege the decedent’s parents’ loss of consortium claim “ceased to be 12 legally viable” upon their deaths and the FAC fails to plead facts sufficient “to support any 13 other form of wrongful death damages.” (Doc. 32 at 4.) Plaintiffs argue Arizona law 14 permits statutory beneficiaries to be compensated for their losses “in proportion to their 15 damages,” including both economic and non-economic damages. (Doc. 36 at 4.) 16 Under Arizona law, a wrongful death claim and a survival claim are separate claims 17 arising from the same incident. Barragan v. Superior Ct. of Pima Cnty., 470 P.2d 722, 725 18 (Ariz. App. 1970); A.R.S. §§ 14-3110, 12-611; see also Gandy v. United States, 437 F. 19 Supp. 2d 1085, 1086 (D. Ariz. 2006). On one hand, a wrongful death claim compensates 20 statutory beneficiaries for their injuries. Barragan, 470 P.2d at 724. On the other hand, 21 survival claims permit recovery for damages for the benefit of the decedent’s estate. Id.

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Navarro v. Santa Cruz, County of, Counsel Stack Legal Research, https://law.counselstack.com/opinion/navarro-v-santa-cruz-county-of-azd-2025.