Christian Williams v. County of San Mateo

MEMORANDUM

Christian R. Williams, who is civilly committed in the State of California, appeals pro se from the district court’s summary judgment in his 42 U.S.C. § 1983 action alleging various constitutional violations against the County of San Mateo and the San Mateo Sheriffs Department (collectively, “the County”), including challenges to conditions of his confinement. We have jurisdiction under 28 U.S.C. § 1291 . We review de novo the district court’s grant of summary judgment. Jones v. Blanas, 393 F.3d 918, 926 (9th Cir.2004). We affirm in part, vacate in part, and remand.

The district court examined Williams’s various conditions of confinement claims under the Eighth Amendment deliberate indifference standard. Because Williams is civilly committed, and not a prisoner, the correct legal standard, as set out by this court in Jones v. Blanas, is that of substantive due process. 393 F.3d at 932 (holding a civil detainee under conditions similar to or more restrictive than the conditions imposed on criminal detainees constituted “punishment,” and therefore violated the civil detainee’s Fourteenth Amendment rights). In addition, neither the district court nor the County provided…