Facts

Rodney Bock, 56, was a farmer and small business owner with a history of mental illness. In late 2009 and early 2010, his psychiatric condition relapsed, requiring a series of psychiatric hospitalizations pursuant to California Welfare and Institutions Code section 5150. Dr. Christopher Barnett and Dr. John S. Zil treated him at Sutter-Yuba Mental Health Services, a bi-county psychiatric facility.

In early 2010, Bock was arrested based on erratic behavior during a psychotic episode. The County of Sutter brought criminal charges, and the superior court ordered Bock released and evaluated for competency to stand trial. Bock experienced another psychotic episode, causing him to miss a court date regarding the competency proceedings. Bock's family notified the Sheriff's Department of his status, and took him to Sutter-Yuba Mental Health Services.

On April 1, 2010, Bock was admitted for an emergency 72-hour psychiatric hospitalization. After he was discharged, the County of Sutter transferred Bock to Sutter County Jail. On April 29, Bock was found hanging in his cell.

The Estate of Rodney Bock, Bock's four daughters, and Bock's parents filed suit against the County of Sutter, the County of Yuba, Sutter County Sheriff J. Paul Parker, Sutter County Jail Division Commander Lewis McElfresh, Sutter County Jail Corrections Lieutenant Norman Bidwell, and Deputy Officers Bobby Joe Little, David Calapini, Shaun Fliehman, and Baljinder Rai. Plaintiffs also sued Sutter-Yuba Mental Health Services staff including psychiatrists John S. Zil, M.D., and Christopher Barnett, M.D., Licensed Vocational Nurses Katy Mullin, Donice McGinnis, and Crisis Counselor Rainbow Crane.

PLAINTIFFS' CONTENTIONS:
Decedent was a successful farmer and small business owner of a family-operated farm and fruit stand business. Plaintiffs contended that despite his history of mental illness, decedent was able to manage his condition and lead a productive life. Plaintiffs claimed that defendants were deliberately indifferent to decedent's serious mental health and medical needs.

On decedent's April 1, 2010 admission for emergency psychiatric hospitalization, he was admitted as a "gravely disabled" individual. The next day, Dr. Barnett found that decedent was still actively psychotic, yet discharged him anyway after less than 24 hours, and the County of Sutter then transferred decedent to Sutter County Jail. On April 19, 2010, the superior court found decedent incompetent to stand trial and ordered that he be transferred to the state hospital for inpatient psychiatric treatment. Napa State Hospital sent County of Sutter notice indicating that it was prepared to admit him, but no steps were taken to effectuate his transfer.

At Sutter County Jail, decedent was placed in solitary confinement. His condition deteriorated, and he stopped taking his prescribed psychiatric medication. On April 24, a nurse referred decedent to the mental health division of the jail based on his psychotic condition, and an unlicensed crisis counselor found him unstable, delusional, and having auditory hallucinations. Neither Dr. Zil, the jail psychiatrist, nor any other staff member provided any mental health follow-up with decedent.

On or about April 28, an inmate housed in the cell next to decedent told Officer Rai that decedent was acting suicidal. Another officer observed decedent's delusional and psychotic state. None of the officers contacted mental health staff. The night of decedent's death, the jail staff did not conduct timely safety checks in decedent's solitary confinement unit. Decedent was found hanging, and was found to have withstood a violent and prolonged episode of self-harm, with blood present throughout the cell.

Plaintiffs claimed the County of Sutter's policies, practices, and procedures violated decedent's constitutional rights and his rights under federal disabilities law, and were a proximate cause of decedent's death. Plaintiffs claimed the county had a practice whereby inmates with serious mental illness would be housed, by policy, in the solitary confinement unit of the jail, without adequate access to mental health care or supervision. There was also no policy in place to notify a doctor when an inmate was displaying psychotic behavior or refusing essential psychiatric medications.

Plaintiffs alleged violations of the Eighth and Fourteenth Amendments, the Americans with Disabilities Act, the Rehabilitation Act, and state law.

DEFENDANTS' CONTENTIONS:
Defendants argued that they were not deliberately indifferent to Bock's mental health needs, that their policies and procedures were adequate, and that their conduct did not cause decedent's suffering or death.

Damages

Decedent's daughters' sought damages for the loss of their father, as well as decedent's pain and suffering at the jail.

Result

The court dismissed plaintiffs' disability rights claims, but allowed the case to proceed. After significant discovery, the parties agreed to settle the dispute for $800,000.

Other Information

As part of the settlement agreement, plaintiffs agreed to provide recommendations for changes to improve the Sutter County Jail's medical and mental health system moving forward. The county agreed to give these recommendations "serious consideration." U.S. Magistrate Judge Edmund F. Brennan conducted three separate settlement conferences with the parties leading up to resolution of the case. FILING DATE: Feb. 24, 2011.