Johnson V. County Of Santa Clara Et Al

Case Background

On October 12, 2018, Andrew Johnson, an Army veteran, filed a civil rights lawsuit in the United States District Court for the Northern District of California, after Santa Clara County mistreated him in its jails.

Officers with the San Jose Police Department intentionally destroyed evidence, leading to Andrew Lee Johnson’s wrongful incarceration for over three years. The destroyed evidence was not discovered until Johnson’s jury trial, where he was ultimately acquitted. During his incarceration, Johnson endured torture in solitary confinement and was denied adequate medical and mental health care.

Defendants in this case include Correctional Officers for the County, namely, Deputy Ruban, Matthew Reeves, Dominguez, Lubrin, Benson, and Does 1-25, the other correctional deputies for the County. The City of San Jose, a municipal corporation, operates the San Jose Police Department (SJPD). Police officers from the City involved are Marco Monzon, Trent Tessler, and Jamie Hall, all acting under the color of law and within the scope of their employment for the City. Additionally, Does 1-25 (City) are employees of the City involved in the alleged actions.

Cause

Andrew Johnson’s legal troubles began after an incident in October 2014, when he shot two men in self-defense after they threatened him with a knife. Despite his acquittal in 2017, Johnson endured over three years of wrongful incarceration in Santa Clara County Jail, where he faced severe mistreatment.

The authorities placed Johnson in solitary confinement for 16 months, denying him medication for his PTSD and traumatic brain injury (TBI), which worsened his mental health issues. The jail’s unhygienic conditions worsened his physical health, leading to toenail fungus and rashes due to unsanitary conditions and inadequate access to clean clothing. He also suffered from insomnia after his medication was abruptly discontinued, and he never received proper dental care.

Johnson filed numerous grievances about the harsh conditions, including the 24/7 nightlight in his cell, but his complaints went unaddressed. He gained 80 pounds due to lack of exercise and poor diet, while painful, ill-fitting sandals exacerbated his foot issues. Despite being a pretrial detainee, presumed innocent, Johnson faced cruel and unconstitutional treatment.

In addition to the physical abuse, Johnson experienced retaliation from correctional staff. He reported a beating by deputies, including one who later murdered an inmate. Johnson’s repeated requests for protection from these officers went unheeded. After speaking out, Johnson faced further retaliation, including transfers to more restrictive units.

His mistreatment continued throughout his trial, where he witnessed further abuses by deputies.

Despite his acquittal on attempted homicide charges, the County delayed Johnson’s release and treated him as if he were still guilty. The County also failed to process his SSI/SSDI applications. When the County finally released him, it left Johnson without necessary medications, causing him to continue his struggle for justice even after his acquittal.

Damages

As a direct result of the Defendants’ actions, Johnson endured severe physical pain and injuries. Additionally, Johnson suffered significant emotional and mental distress, including fear, terror, anxiety, depression, humiliation, public embarrassment, and a loss of his sense of security, dignity, and pride. He also developed an irreparable distrust of authority figures. His physical symptoms included insomnia, disrupted eating habits, night terrors, bruises, swelling, and ongoing pain.

Furthermore, as a result of the Defendants’ conduct, Johnson would experience a loss of future income, the exact amount to be determined at trial. He would also require continued mental health counseling, psychological therapy, and medication.

The individual Defendants acted with malice, sadism, wantonness, and oppression. Their conduct showed reckless disregard for Johnson’s rights and dignity.

Johnson respectfully requested that the Court:

  1. Award general, special, and compensatory damages, to be determined at trial.
  2. Award punitive damages against the individual Defendants for their extreme and outrageous actions that disregarded Johnson’s constitutional rights.
  3. Award statutory damages and attorney’s fees against all Defendants as permitted under 42 U.S.C. §1988.
  4. Award statutory damages and attorney’s fees against all Defendants under Title I and II of the ADA and Sections 501 and 504 of the Rehabilitation Act.
  5. Grant any other relief the Court finds just and proper.

Key Arguments and Proceedings

Legal Representation

  • Plaintiff(s): Andrew Lee Johnson
    • Counsel for Plaintiff(s): Dmitry Stadlin | Robert Ross Powell | Sarah Elizabeth Marinho
  • Defendant(s): County of Santa Clara | Deputy Ruban | Matthew Reeves | Deputy Dominguez | Jereh Lubrin | Jonathan Benson | City of San Jose | Marco Monzon | Jamie Lee Nicholas Hall | Trent Tessler
    • Counsel for Defendant(s): Bryan K. Anderson | Winifred Botha | David Michael Rollo | David John Stock | Jon Heaberlin | Susan Pearl Greenberg | Maren Jessica Clouse | Wesley Klimczak |

Claims

First Cause of Action (Fourteenth Amendment – Cruel and Unusual Punishment, 42 U.S.C. § 1983)
(Against Defendants Ruban, Matthew Reeves, Lubrin, and Does 1-25)

Defendants Ruban, Matthew Reeves, Lubrin, and Does 1-25 acted under color of law, violating Johnson’s basic human dignity and rights under the Fourteenth Amendment. Their actions subjected Johnson to cruel and unusual punishment, including excessive force.

Second Cause of Action
(Fourteenth Amendment – Cruel and Unusual Punishment, 42 U.S.C. § 1983 – Monell Liability)
(Against Defendant County)

From his booking in 2014 until his release in 2018, Johnson was unlawfully detained under conditions that violated his rights. The County was aware of ongoing constitutional violations by its staff but failed to act. These practices, including excessive force and cruel punishment, directly caused Johnson’s harm. The County’s deliberate indifference led to these constitutional rights violations.

Third Cause of Action
(Intentional Infliction of Emotional Distress – Conspiracy between Ruban, Matthew Reeves, and Dominguez)

Defendants Ruban, Reeves, and Dominguez engaged in extreme and outrageous conduct to harm and intimidate Johnson. Their actions caused severe emotional distress.

Fourth Cause of Action
(California Civil Code § 52.1)

(Against Defendants Ruban, Matthew Reeves, Lubrin, Does 1-25, and County)
The conduct of Defendants violated California Civil Code § 52.1, interfering with Johnson’s constitutional rights.

Fifth Cause of Action
(Americans with Disabilities Act, 42 U.S.C. § 12101, et seq.)
(Against County)

The County failed to accommodate Johnson’s disabilities, violating the ADA.

Sixth Cause of Action
(Section 504 of the Rehabilitation Act)
(Against County)

The County discriminated against Johnson based on his disability, violating Section 504.

Seventh Cause of Action
(Fourth and Fourteenth Amendments – Continued Unlawful Detention, Malicious Prosecution, 42 U.S.C. § 1983)
(Against Defendants Marco Monzon, Jamie Lee Nicholas Hall, Trent Tessler, and Does 1-25)

Defendants acted under color of law to unlawfully detain Johnson, violating his constitutional rights. As a result, Johnson suffered damages, and punitive damages apply.

Eighth Cause of Action
(Fourth and Fourteenth Amendments – Continued Unlawful Detention, Malicious Prosecution, 42 U.S.C. § 1983 – Monell Liability)
(Against Defendant City)

The City, aware of ongoing violations of his constitutional rights, failed to prevent unlawful detention and prosecution. This deliberate indifference caused harm, and Johnson sought damages and punitive relief.

Defense

Defendant asserted that the First Amended Complaint failed to state a valid claim for relief. Additionally, Defendant argued that Plaintiff intentionally shot two individuals in 2014, which led to his arrest by San Jose police, who had probable cause to detain him. As a result, the City of San Jose and the arresting officers were immune from liability under California Penal Code § 836.5.

Defendant claimed entitlement to qualified immunity, asserting that their actions were reasonable and did not violate any clearly established constitutional rights of Plaintiff. Furthermore, the California Government Code protected the City of San Jose and the arresting officers from liability.

Defendant denied any unconstitutional conduct toward Plaintiff, asserting that any claims to the contrary were false. Plaintiff’s request for punitive damages was barred by California Government Code Section 818. Defendant also claimed immunity under several provisions of the Government Code, including sections 820.2, 820.4, and 820.8.

Defendant maintained that any loss or destruction of officers’ notes was unintentional and did not contribute to Plaintiff’s arrest or conviction. Moreover, Plaintiff’s claims were barred due to failure to comply with the Government Claims Act or file within the required statute of limitations.

Defendant was immune from state law claims under Government Code section 820.8, which granted immunity for injuries caused by others. Finally, Defendant argued that Plaintiff’s claims were reduced due to Plaintiff’s own negligence or the actions of others and that the alleged conduct did not violate any constitutional rights.

Jury Verdict

On March 21, 2023, the Court granted summary judgment in favor of Defendant Trent Tessler, dismissing all claims Plaintiff Andrew Lee Johnson brought against him. The Court also dismissed Plaintiff’s claims against Defendants Marco Monzon and Jamie Hall, including claims for deliberate fabrication of evidence, malicious prosecution, and unlawful detention.

Plaintiff’s remaining claims against Officers Monzon and Hall, and the City of San Jose, were then tried before a jury. On February 21, 2024, the jury returned a verdict in favor of the Defendants, rejecting all of Plaintiff’s remaining claims.

Therefore, pursuant to Federal Rule of Civil Procedure 58, on March 11, 2024, Judge Edward J. Davila entered a judgment in favor of Defendants Trent Tessler, Marco Monzon, Jamie Hall, and the City of San Jose.

Court Documents:

Available upon request