Facts

Three weeks before his death, Russell Cotton was involuntarily committed to a hospital due to bizarre and threatening behaviors toward his family. Upon his release, he was arrested and released multiple times. The Santa Barbara Sheriff's Dept. and Mental Health Assessment Team (MHAT) located Cotton after his release and he was taken to Lompoc Hospital for medical clearance before being admitted to the County's Psychiatric Health Facility (PHF). Dr. Irwin Lunianski was the on-call psychiatrist for the Santa Barbara County Alcohol, Drug, and Mental Services at the time Cotton was admitted, and Lunianski placed Cotton on a 72 hour psychiatric hold after he was medically cleared at the hospital. Cotton subsequently kicked out the rear window of the MHAT vehicle, and he was arrested and taken to jail. Due to his violent behaviors, his transfer to PHF was delayed because a number of deputies would be required. On Nov. 6, 2002, Cotton was being transferred within the jail when he started to exhibit belligerent behaviors. A struggle ensued and numerous deputies were involved in an attempt to subdue him. He was eventually subdued and placed in a safety cell, un-handcuffed. Shortly thereafter, the deputies noticed he was turning blue and that he was unresponsive. His heartbeat was restored at the Cottage Hospital, but he died several days later.

Cotton's survivors filed suit against Martinez, Avila, McWilliams, Guerra, Coburn, Turner (Sheriff's Deputies), and Lunianski alleging deliberate indifference to his serious medical needs, which resulted in his death.

PLAINTIFFS' CONTENTIONS:
Plaintiffs contended that Lunianski should have admitted Cotton to the PHF and the subsequent scuffle with the deputies at the jail would not have occurred. Plaintiffs also alleged that Martinez used excessive force when he pushed Cotton against a wall in the jail in order to prevent him from running away. Plaintiffs contended that Cotton died of asphyxiation.

DEFENDANTS' CONTENTIONS:
Lunianski denied having refused Cotton's admission to the PHF, and the Deputies denied being deliberately indifferent to Cotton's medical needs when they left him in the safety cell. The defendants and their experts contended that Cotton died of causes other than asphyxiation.

Result

The jury returned a verdict in favor of Martinez on the claim of excessive force, and in favor of Lunianski, Avila, McWilliams, Guerra, Coburn and Turner on the claim of deliberate indifference to medical needs. The jury hung on the claim of deliberate indifference to medical needs against Defendant Martinez.