Miranda-Rivera v. Toledo-Davila, No. 14-1535 (1st Cir. 2016)
Annotate this CaseDefendant was arrested for driving under the influence. Shortly after he was brought by Puerto Rico Police Department officers to the police station, he died in a holding cell. Defendant’s family members and estate filed suit, alleging that Defendants - Officer Perez, Sergeant Rodriguez, and Superintendent Toledo - used excessive force against Defendant and denied him needed medical care in violation of 42 U.S.C. 1983. The district court granted summary judgment in favor of Defendants on the grounds of sovereign immunity and insufficient evidence. Plaintiffs appealed, challenging only the district court’s decisions on the excessive force and denial of medical care claims and supervisory liability. The First Circuit (1) reversed and remanded for trial Plaintiffs’ claims against Perez and Rodriguez, holding (i) Perez and Rodriguez were not entitled to qualified immunity on the excessive force claim or the denial of medical care claim; and (2) affirmed the district court’s grant of summary judgment on Plaintiffs’ claims against Toledo, holding that Plaintiffs did not adequately plead facts going to Toledo’s liability.
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