Wallace Shah v. County of Los Angeles, Deputy Sheriff W. Corette, Deputy Sheriff Matsumoto

Wallace Shah sued Los Angeles County Deputy Sheriffs Corette and Matsumoto (“the deputies”) and the County of Los Angeles (“County”) under 42 U.S.C. § 1983 for allegedly unconstitutional actions committed while Shah was in pretrial detention in the Los Angeles County Jail. Shah alleged that the deputies assaulted and harassed him, denied him medical treatment, and opened his mail without his consent, in violation of his right not to be deprived of liberty without due process of law guaranteed by the fourteenth amendment. Shah further alleged that the deputies’ mistreatment was pursuant to a policy, custom or practice of Los Angeles County to intimidate prisoners from seeking legal redress to ameliorate the conditions of confinement in the County Jail.

The district court dismissed Shah’s claims against the deputies, holding that the availability of an adequate post-deprivation state law remedy barred a section 1983 suit alleging a violation of fourteenth amendment liberty interests under the doctrine of Parratt v. Taylor, 451 U.S. 527, 540-44 , 101 S.Ct. 1908, 1915-17 , 68 L.Ed.2d 420 (1981). The district court also dismissed Shah’s suit against the County for failure to state a…