Facts

Joshua Sanchez and Y. Cheng worked as Custody Assistants at the Twin Towers Correctional Facility (TTCF) in Los Angeles, while J. Zavala, and O. Estrada were Sheriff's deputies. While working at TTCF, Sanchez applied to and was accepted into the Los Angeles County Sheriff's Academy. On November 29, 2019, approximately one week prior to his start date at the Sheriff's Academy, Sanchez announced to the others that it was his final day at TTCF. Zavala drew his taser and acted like he was going to tase Sanchez's left leg. As Sanchez was rolling away in his wheeled office chair, the taser hit his finger. Cheng then motioned for Estrada's taser and Estrada gave his teaser to Cheng, who tased Sanchez in the right thigh. Sanchez attempted to resume his job duties that day, but was unable to do so because he was in too much pain from the incident. He went to the emergency room in San Dimas Community Hospital for treatment. County policy prohibited hazing, bullying, and using tasers on fellow employees. Custody Assistants like Cheng were not given any authority to use a taser. The County of Los Angeles investigated the incident, and ultimately Cheng and Zavala were disciplined. On November 15, 2021, Sanchez brought a lawsuit against the County of Los Angeles, Y. Cheng, J. Zavala, and O. Estrada, alleging violations of the First, Fourth, and Fourteenth Amendments.

PLAINTIFF'S CONTENTIONS: Plaintiff contended that defendants violated his constitutional rights when the individual defendants subjected him to the taser "hazing ritual" before he enrolled at the Los Angeles County Sheriff's Academy. Further, plaintiff maintained that the individual defendants were acting "under color of state law" at the time the incident occurred. Plaintiff urged the court to apply a strong presumption of state action because the defendants were all on-duty at the time of the incident. Even without this lower standard, plaintiff alleged that the actions of the individual defendants were attributed to the state because they used their position to assert influence and control over him. Finally, plaintiff argued that the defendant county affirmatively placed plaintiff in danger since they were aware of the hazing rituals yet failed to take sufficient action.

DEFENDANTS' CONTENTIONS: Defendants conceded that Cheng or Zavala used their tasers on Sanchez while at the Twin Towers Correctional Facility. However, defendants argued that Cheng was not acting under color of law and could not be held individually liable because he used a taser that was not afforded to him in his position with the County in a setting and manner completely unrelated to his official duties. Meanwhile, defendants maintained that Estrada and Zavala were not acting under color of law because their actions were not related to their official duties, other than the fact their tasers were used.

Result

The court granted summary judgment and entered judgment for defendants.