Roberts v. County of Kern

CourtDistrict Court, E.D. California
DecidedMarch 5, 2025
Docket1:21-cv-00725
StatusUnknown

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

Bluebook
Roberts v. County of Kern, (E.D. Cal. 2025).

Opinion

1 2 3 4 5 6 7 8 UNITED STATES DISTRICT COURT 9 FOR THE EASTERN DISTRICT OF CALIFORNIA 10 11 Willie Roberts and Carla Sutton, No. 1:21-cv-00725-KJM-CDB 12 Plaintiffs, ORDER 13 v. County of Kern, et al., 1S Defendants. 16 17 In this action, plaintiffs Willie Roberts and Carla Sutton allege Kern County Sheriff's 18 | Deputies shot Roberts in the thigh, aimed a rifle at Sutton’s head, detained her for several hours in 19 | handcuffs, and seized her car and phone during the search of a suspected casino in Bakersfield, 20 | California. Roberts and Sutton claim the officers, the County and the Sheriffs Office deprived 21 | them of their Fourth Amendment rights and violated California law. The matter is before the 22 | court on the defendants’ motion for summary judgment, which is fully briefed. See Mot., ECF 23 | No. 26; Mem., ECF No. 26-1; Opp’n, ECF No. 27; Reply, ECF No. 29. The court has reviewed 24 | the record and the parties’ briefs and submits the matter on the record before it. See E.D. Cal. 25 | L.R. 230(g). As explained in this order, genuine disputes of material fact prevent the court from 26 | concluding that defendants are entitled to judgment as a matter of law with respect to a majority 27 | of plaintiffs’ claims. The motion for summary judgment is granted in part and denied in part.

1 I. EXCESSIVE FORCE 2 A. Roberts’s Claim against Geherty 3 Roberts alleges defendant Brandon Geherty, a Kern County Sheriff’s Deputy, used 4 excessive force by shooting him in the upper thigh. As required at this stage, the court views the 5 evidence in the light most favorable to Roberts and draws reasonable inferences in his favor. See 6 Matsushita Elec. Indus. Co. v. Zenith Radio Corp., 475 U.S. 574, 587–88 (1986); Adickes v. S.H. 7 Kress & Co., 398 U.S. 144, 157 (1970). Viewed in that light and with the benefit of those 8 favorable inferences, the evidence in this case would show Geherty accidentally shot Roberts in 9 his thigh while Roberts was detained and lying peacefully on the ground at the deputy’s feet, 10 under suspicion of no violent crime. See Roberts Dep. at 26–27, 48–49, 56–57, 62, 11 ECF No. 27-3. Roberts and Geherty agree the shots were accidental; they differ only in their 12 accounts of what Roberts was doing at the time. See generally, e.g., Geherty Decl., Defs.’ Ex. C, 13 ECF No. 26-4. The evidence also shows the Kern County Sheriff’s Office instructs its deputies 14 (1) to assume all guns are always loaded, (2) never to let the muzzle of a firearm cover anything 15 they are “not willing to shoot or destroy,” (3) to keep their “finger off the trigger and outside the 16 trigger guard until you are going to shoot,” and (4) to “[b]e sure of your target and beyond/ 17 surrounding.” Pls.’ Ex. 9 at 146,1 ECF No. 27-3. 18 An accidental or mistaken shooting can be unreasonable and therefore contrary to the 19 Fourth Amendment. See, e.g., Torres v. City of Madera (Torres II), 648 F.3d 1119, 1124 20 (9th Cir. 2011); Torres v. City of Madera (Torres I), 524 F.3d 1053, 1054 (9th Cir. 2008); Henry 21 v. Purnell, 501 F.3d 374, 383 (4th Cir. 2007); Jensen v. City of Oxnard, 145 F.3d 1078, 1086 22 (9th Cir. 1998). The question is whether the mistaken use of deadly force was “objectively 23 unreasonable under the totality of the circumstances.” See Torres II, 648 F.3d at 1124. Those 24 circumstances include, among others, whether the officer had received training to prevent the type 25 of accident in question, whether he acted in accordance with that training, and whether following 26 that training in the moment would have prevented the accident. Id. at 1125. It is also relevant 1 Page numbers cited in this exhibit are those applied to the top right of each page by the CM/ECF system. 1 whether the defendant’s actions “heightened the officer’s sense of danger” or “caused the officer 2 to act with undue haste and inconsistently with [his] training.” Id. (quoting Torres I, 524 F.3d at 3 1057). 4 Here, again, viewing the evidence in the light most favorable to Roberts and drawing 5 inferences in his favor, it would be reasonable to find that Geherty would not have shot Roberts if 6 Geherty had followed the Sheriff’s Office’s training—not to allow the muzzle of his rifle to cover 7 Roberts, to keep his finger off its trigger and outside its trigger guard, and to be sure of his 8 surroundings. A jury also could reasonably conclude this training was intended to avoid similar 9 accidental shootings. Finally, a jury could find Roberts was doing nothing to heighten Geherty’s 10 sense of danger or to force any action in undue haste. As noted above, it would be reasonable to 11 find Roberts was lying peacefully on the ground below Geherty, was not suspected of any violent 12 crime, and was not attempting to flee. An accidental shooting in these circumstances would be 13 objectively unreasonable. 14 The relevant law was clearly established at the time. The Ninth Circuit had held for many 15 years that officers are not entitled to qualified immunity when they use deadly force by making 16 unreasonable mistakes in circumstances such as this. See Torres II, 648 F.3d at 1128–29 17 (reversing district court’s order granting qualified immunity because relevant law was “clearly 18 established”). This court is bound by that holding. “While a jury might ultimately find [Deputy 19 Geherty’s] mistake . . . to have been reasonable,” it would be “inappropriate for [this] court to 20 reach this conclusion in the face of material disputes of fact.” Id. at 1129. Geherty is therefore 21 not entitled to qualified immunity. The court denies his motion for summary judgment of this 22 claim. 23 B. Sutton’s Claim Against Brock 24 Sutton was in her car near the scene of the search, near where Roberts was shot. When 25 the evidence is viewed in the light most favorable to Sutton’s case, it would show defendant Ryan 26 Brock, also a Kern County Sheriff’s Deputy, opened her car’s passenger door, jumped into the 27 passenger seat beside her and aimed a rifle at her head, its muzzle only a few inches from her 28 face. See Sutton Dep. at 30–34, ECF No. 27-3. A jury could reasonably find on this record that 1 Brock did not suspect her of having committed a violent or dangerous crime and she was not 2 attempting to flee, resisting or otherwise disobeying or disregarding any instructions. 3 It was clearly established at the time that an officer may not aim a deadly weapon at a 4 person who is not suspected of a violent crime, not resisting, not disobeying instructions and not 5 attempting to flee. See, e.g., Thompson v. Rahr, 885 F.3d 582, 586–87 (9th Cir. 2018); Espinosa 6 v.City & County of San Francisco, 598 F.3d 528, 537–38 (9th Cir. 2010); Hopkins v. Bonvicino, 7 573 F.3d 752, 776–77 (9th Cir. 2009); Tekle v. United States, 511 F.3d 839, 846 (9th Cir. 2007); 8 Robinson v. Solano County, 278 F.3d 1007, 1015–16 (9th Cir. 2002) (en banc). The court denies 9 Brock’s motion for summary judgment of this claim. 10 C.

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Roberts v. County of Kern, Counsel Stack Legal Research, https://law.counselstack.com/opinion/roberts-v-county-of-kern-caed-2025.