Facts

Candace Steel was arrested for an outstanding warrant and child endangerment by Alameda County Sheriff's Office on July 20, 2017, at a homeless encampment adjacent to the I-580 freeway in Castro Valley, CA. She was with her boyfriend and two-year- old daughter. The encampment was filled with garbage and they were sleeping next to an open hole with human feces. The two-year-old, Jane Doe, was filthy. She was found with dried fecal matter on her skin, had matted hair, and an upper respiratory infection. Ms. Steel identified herself as approximately eight months pregnant but had not received any prenatal care. She was medically evaluated at Valley Care Medical Center in Pleasanton, CA and cleared for incarceration before being brought to Santa Rita Jail. After the intake process, Ms. Steel was assigned to dormitory-style housing in Housing Unit 24.

On July 21, 2017, at approximately 1951 hours, Ms. Steel was transported "Code 3" to Valley Care Medical Center after her water broke. She was cleared by hospital medical staff to return to Santa Rita Jail and returned to the outpatient housing unit ("OPHU"). On July 22, 2017 at 0942 hours, Ms. Steel was medically cleared by Wellpath, the medical group which provides comprehensive medical services to inmates at Santa Rita Jail, to return to Housing Unit 24. On Friday, July 23 at about 0835 hours, Ms. Steel was again medically evaluated by Wellpath and cleared to remain in her housing unit.

Later on July 23, 2017, at approximately 1725 hours, Ms. Steel was involved in a verbal altercation with several inmates in lower C pod of Housing Unit 24. An inmate threatened to "snap her neck" if Ms. Steel continued to push the emergency call button (Ms. Steel had pushed the button several times as a result of discomfort). ACSO deputies placed Ms. Steel in the East Temporary Holding Cell for her own safety with a mattress, pillow, and a bed roll while awaiting a reclassification order to move the inmate who had been threatening Ms. Steel to a different housing area. Ms. Steel's cell had a toilet, sink, and an intercom to the Sheriff's Technician. After the threatening inmate had been removed, Deputies attempted to return Ms. Steel to lower C pod. However, Ms. Steel wanted to stay in the east temporary holding cell and told deputies that she could not return to lower C pod because there were other inmates making threats towards her and that she was in fear for the safety of her baby. Ms. Steel confirmed at her deposition that she feared for her safety as a result of threats from other inmates. At her request, Ms. Steel was returned to the East Temporary Holding Cell where she would remain until she could be reassigned to OPHU. At about 1855 hours on July 23, while in the East Temporary Holding Cell, Ms. Steel informed a deputy that she was experiencing minor vaginal bleeding and pressure in her lower abdomen. Ten minutes later at about 1905 hours, Ms. Steel was seen by Wellpath medical staff in the HU24 sick call room, cleared by Wellpath and then returned to the East Temporary Holding Cell. At approximately 2052 hours, Ms. Steel began hitting the cell door and yelling for help (the cell also had an intercom button to the on-duty Sheriff's technician). ACSO and Wellpath staff immediately responded to the Temporary Holding Cell to assist Ms. Steel in the aftermath of Baby H's birth until she was transported by ambulance to Valley Care Medical Center for further care.

PLAINTIFFS' CONTENTIONS: Plaintiffs contended that plaintiff Steel was complaining about pain and had high-risk early delivery symptoms, but defendants disregarded them and ignored plaintiff Steel's screams. Plaintiffs further contended that the information about plaintiff Steel's potential risks for premature labor was noted in her intake form at the jail, which should have alerted the jail staff that she was a higher than normal pregnancy risk. Plaintiffs contended that defendants engaged in barbaric conduct by forcing plaintiff Steel to give birth alone in a dirty, concrete cell without blankets or towels. Plaintiffs asserted that the way defendant CFMG's contract is structured, it has a financial incentive to prevent pregnant women from receiving proper medical care because, under the terms of the contract, defendant CFMG must pay for any outside hospitalization costs itself and receives no reimbursement from the county, including for labor and delivery services. Plaintiffs alleged that their injuries arose out of the defendant sheriff's office's contract with defendant CFMG, which contained financial terms that discouraged adequate medical care, including procedures such as labor and delivery, for detainees. As such, plaintiffs contended that defendants have in place a practice or policy that manifested deliberate indifference to plaintiffs' constitutional rights to adequate medical care. Plaintiffs also alleged that defendants' failure to provide adequate medical care to plaintiffs constituted extreme and outrageous conduct by the defendants with the intention of causing, or reckless disregard of the probability of causing, emotional distress, and that plaintiffs suffered and continue to suffer extreme emotional distress, which was caused by the defendants' outrageous conduct. Plaintiffs further alleged that Santa Rita Jail was not equipped with labor or delivery rooms or with other necessary and basic equipment and facilities that are needed to care for women in childbirth, and that defendant CFMG staff at the jail are not trained in caring for women in childbirth, and thus, this state of affairs supported a finding of deliberate indifference in that the jail lacked appropriate facilities to treat plaintiffs. Plaintiffs further alleged that the defendants knew that this policy might lead to a constitutional violation among its inhabitants because it was bound by regulations aimed at mitigating the risk of serious injury to pregnant women in jail.

DEFENDANTS' CONTENTIONS: Defendants denied all contentions. Defendants contended that plaintiffs' complaint did not plausibly allege that plaintiffs' injuries were the result of a government pattern, practice, or custom. Defendants claimed that plaintiffs' claims for infliction of emotional distress were barred by the California statutory immunity. ACSO and Wellpath staff treated Ms. Steel with nothing but the utmost compassion and respect despite the stressful circumstances.

Result

The case settled for $250,000. Defendants denied and did not admit any liability as part of the settlement. Alameda County did not contribute financially to the settlement.