Miriam Mendiola-Martinez v. Joseph Arpaio

We recently recognized that only rarely will prisoners’ medical needs “genuinely clash” with the security concerns of prison personnel. Chess v. Dovey, 790 F.3d 961, 974 (9th Cir. 2015). That discord may be present when the prisoner is a woman in labor. Miriam Mendiola-Martinez was in the custody of Maricopa County for a nonviolent offense when she gave birth to her son. After her release, she filed suit under 42 U.S.C. §§ 1981 & 1983, alleging that her constitutional rights were violated when, among other things, she was shackled and restrained during labor and postpartum recovery. Mendiola-Martinez brought her claims against Maricopa County and Sheriff Joe Arpaio (collectively “the County Defendants”), the Maricopa County Special Health Care District (“the Medical Center”) where she had her baby, and individual John and Jane Doe defendants. The district court granted summary judgment for the County Defendants and the Medical Center on all of Mendiola-Martinez’s claims, and taxed costs against her. She now appeals the summary judgment orders and the cost awards, both of which we have jurisdiction to review under 28 U.S.C. § 1291 .

We are presented with an important and…