This federal lawsuit pending before the Honorable Anthony Battaglia, U.S. District Judge for the Southern District of California, challenges the County of San Diego, San Diego County Sheriff’s Office (formerly “Department”), and San Diego County Probation Department for their collective failure to provide adequate, accessible and safe living conditions, and medical, mental health or dental care for people incarcerated in county jails.  It also seeks to address the rights of individuals to pursue claims without attorney representation, to have access to counsel and to address over-incarceration in San Diego County Jails of people of color.

Named plaintiff Darryl Dunsmore filed this lawsuit without legal representation in 2020.  In February 2022, now represented by Class Counsel, Mr. Dunsmore and additional named plaintiffs amended the complaint to include class action allegations on behalf of all individuals who are or will be incarcerated in the County’s jails, with an amended complaint filed in November 2022, which is available here.  The lawsuit includes eight claims for class relief, including the Third Claim for Relief, which seeks relief under the Americans with Disabilities Act, Rehabilitation Act, and California Government Code §11135.

On November 3, 2023, the Court approved parties’ joint motion for class certification, certifying one class and three subclasses.  The Court’s order is here.  The Class Notice is here.

On December 11, 2024, the San Diego Board of Supervisors approved a comprehensive settlement agreement to resolve Plaintiffs’ claims under the Americans with Disabilities Act (“ADA”) and related state law.  On March 3, 2025 Judge Battaglia granted preliminary approval to the settlement.  That order is here.

The proposed settlement agreement follows an initial ADA settlement agreement reached in 2023, after the Plaintiffs filed a preliminary injunction motion to seek accessible housing for people with mobility disabilities at the downtown San Diego Central Jail, as well as access to sign language interpreting services.  As a result of that initial settlement, the Sheriff’s Office has undertaken renovations to Central Jail to make it more accessible to people who use wheelchairs or have other mobility disabilities.  The Sheriff’s Office has also begun offering sign language interpretation to deaf people through video remote interpreting, and other methods.

After extensive fact discovery and the exchange of expert reports, the Sheriff’s Office agreed to enter into a more comprehensive settlement agreement to resolve the remainder of Plaintiffs’ claims for disability discrimination and denial of access to programs, services and activities. Plaintiffs’ expert reports on ADA issues are here and here.  The proposed settlement of the disability claim requires additional significant changes to the Jail’s policies, procedures, and practices for accommodating individuals with disabilities including those with mental health needs and intellectual disabilities.  The proposed settlement also requires physical construction at several Jail facilities to provide accessible housing to people with disabilities. The proposed settlement has been submitted to the Court for preliminary approval.  Information about the Settlement Notice and Fairness Hearing will be posted here as soon as available.

The March 3, 2025 order granting preliminary approval and approving Plaintiffs’ proposal for class notice is important because this case included an unusual situation where the parties had competing proposals for the distribution of the class notice, as opposed to agreeing on the method of distribution.  The order therefore includes analysis about the effectiveness of competing proposals for distributing a notice of settlement to a class, particularly an incarcerated class.  Judge Battaglia’s order approving Plaintiffs’ proposed method for distribution sets forth clear principles about how to ensure effective class notice for an incarcerated population, including posting the notice in large font and on white paper (as opposed to transparencies) and handing the notice directly to incarcerated people entering the jail.  The approved class notice is here.

Seven other claims in the case remain ongoing and in active litigation.  Highly qualified experts have opined on each of the claims; those reports can be found under the “Expert Declarations” tab on this page.  Defendants have moved for summary judgment on 6 of the 7 remaining claims in the case.  A hearing on Defendants’ motion will be held May 8.  Pre-trial procedures will begin 30 days after the Court rules on the motion. 

 

 

 

 

 

In November 2022, Plaintiffs filed the third amended class action complaint in this case:

Third Amended Civil Class Action Complaint for Declaratory and Injunctive Relief, 11-18-2022

Reply-Decl-Christiansen-ISO-Pltfs-Motions-for-PI-and-Provisional-Class-Cert_-06-07-2022

Reply-Decl-Lewis-ISO-Pltfs-Motions-for-PI-and-Class-Cert_-06-07-2022

Reply-Decl-Moore-ISO-Pltfs-Motions-for-PI-and-Class-Cert_-06-07-2022

Reply-Decl-Ross-ISO-Pltfs-Motions-for-PI-and-Class-Cert_-06-07-2022

Reply-Decl-Sepulveda-ISO-Pltfs-Motions-for-PI-and-Class-Cert_-06-07-2022

Reply-Decl-Tozer-ISO-Pltfs-Motions-for-PI-and-Class-Cert_-06-07-2022

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Reply-Decl-Zoerner-ISO-Pltfs-Motions-for-PI-and-Class-Cert_-06-07-2022

Decl of Anthony Ray Edwards ISO Pls Motions for PI and Provisional Class Certification, 05-02-2022

Decl of Cedrick Jones ISO Pls Motions for PI and Provisional Class Certification, 05-02-2022

Decl of Christopher Nelson ISO Pls Motions for PI and Provisional Class Certification, 05-02-2022

Decl of Christopher Norwood ISO Pls Motions for PI and Provisional Class Certification, 05-02-2022

Decl of Daniel Webb ISO Pls Motions for PI and Provisional Class Certification, 05-02-2022

Decl of Darryl Lee Dunsmore ISO Pls Motions for PI and Class Certification, 05-02-2022

Decl of Robert Hollon ISO Pls Motions for PI and Provisional Class Certification, 05-02-2022

Decl of Waylon Cozart ISO Pls Motions for PI and Provisional Class Certification, 05-02-2022

Decl of David Francis Smith ISO Pls Motions for PI and Class Certification, 05-02-2022

Decl of Dion Scott Bucklelew ISO Pls Motions for PI and Class Certification, 05-02-2022

Decl of Dylan Lacroix ISO Pls Motions for PI and Provisional Class Certification, 05-02-2022

Decl of Ernest Archuleta ISO Pls Motions for PI and Provisional Class Certification, 05-02-2022

Decl of Gary Bartlett ISO Pls Motions for PI and Provisional Class Certification, 05-02-2022

Decl of Gustavo Sepulveda ISO Pls Motions for PI and Provisional Class Certification, 05-02-2022,

Decl of Isaiah Glenn ISO Pls Motions for PI and Provisional Class Certification, 05-02-2022

Decl of James Clark ISO Pls Motions for PI and Provisional Class Certification, 05-02-2022

Decl of Jose Antonio Lopez ISO Pls Motions for PI and Provisional Class Certification, 05-02-2022

Decl of Joshua Roberts ISO Pls Motions for PI and Provisional Class Certification, 05-02-2022

Decl of Josue Lopez ISO Pls Motions for PI and Provisional Class Certification, 05-02-2022

Decl of Katrina Rios ISO Pls Motions for PI and Provisional Class Certification, 05-02-2022

Decl of Mark Baker ISO Pls Motions for PI and Provisional Class Certification, 05-02-2022

Decl of Michael Keavney ISO Pls Motions for PI and Provisional Class Certification, 05-02-2022

Decl of Nikki Yach ISO Pls Motions for PI and Provisional Class Certification, 05-02-2022

Decl of Reanna Levy ISO Pls Motions for PI and Provisional Class Certification, 05-02-2022

Expert Reports Regarding Disability Access 

(Please contact Gay Grunfeld at ggrunfeld@rbgg.com if you are interested in viewing the exhibits to these two reports re disability access.)

Expert Report of Syroun Sanossian, 8/21/24

Rebuttal Expert Report of Syroun Sanossian, 10/2/24

Expert Reports Regarding Inadequate Dental Care

Expert Report of Jay Shulman, 8/20/24

Rebuttal Expert Report of Jay Shulman, 10/31/24 

Expert Reports Regarding Inadequate Health Care

Expert Report of Jeffrey Keller, 8/21/24

Rebuttal Expert Report of Jeffrey Keller, 11/1/24

Expert Reports Regarding Inadequate Mental Health Care

Expert Report of Pablo Stewart, 8/19/24

Rebuttal Expert Report of Pablo Stewart, 10/31/24

Expert Reports Regarding Inadequate Safety and Security

Expert Report of James Austin, 8/21/24

Rebuttal Expert Report of James Austin, 10/2/24 

Plaintiffs Rule 26a2A Disclosure of Non-Retained Expert Paul Parker, 8/21/24

Rebuttal Expert Report of Paul Parker, 10/2/24

Expert Report of Gary Raney, 8/21/24

Rebuttal Expert Report of Gary Raney, 10/2/24  

Expert Reports Regarding Inadequate Treatment for Substance Use

Expert Report of Kelly Ramsey, 8/20/24

Rebuttal Expert Report of Kelly Ramsey, 11/1/24

Expert Reports Regarding Lack of Access to Alternatives to Incarceration

Expert Report of Christine Scott-Hayward, 8/15/24

Rebuttal Expert Report of Christine Scott-Hayward, 10/1/24

Expert Reports Regarding Racial Discrimination

Expert Report of Matthew B Ross, 08-21-2024

Rebuttal Expert Report of Matthew Ross, 10-02-2024

Expert Reports Regarding Unconstitutional Denial of Access to Courts and Counsel

Expert Report of Karen Snell, 8/7/24

Rebuttal Expert Report of Karen Snell, 10/1/24

Expert Reports Regarding Unconstitutional Environmental Conditions

Expert Report of Debra Graham, 01-03-2025

Rebuttal Expert Report of Debra Graham, 10/1/24

Expert Declarations from 2022

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Reply-Decl-Stewart-ISO-Pltfs-Motions-for-PI-and-Class-Cert_-06-07-2022

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Reply-Decl-Sanossian-ISO-Pltfs-Motions-for-PI-and-Class-Cert_-06-07-2022

Decl of James Austin ISO Pltfs Motions for PI and Provisional Class Cert, 05-02-2022

Decl of Pablo Stewart ISO Pls Motions for PI and Provisional Class Certification, 05-02-2022

Decl of Robert Cohen ISO Pls Motions for PI and Provisional Class Certification, 05-02-2022

Decl of Syroun Sanossian ISO Pls Motions for PI and Provisional Class Certification, 05-02-2022

Decl of Evans ISO Pls Motions for PI and Provisional Class Certification, 05-02-2022

Decl of Jennifer Alonso ISO Pls Motions for PI and Provisional Class Certification, 05-02-2022

‘Filthy’ and ‘deplorable’: San Diego jails fall short of minimum health standards, expert says in lawsuit, San Diego Union Tribune, January 15, 2025

Plaintiffs challenging San Diego County jail practices want a court order to depose sheriff, San Diego Union Tribune, May 7, 2024

Repeated failures by San Diego County jail health provider prompt sheriff to order it to fix deficiencies, San Diego Union Tribune, March 31, 2024

San Diego County loses another round in its long-running effort to keep sheriff’s records private, San Diego Union Tribune, March 8, 2024

San Diego Sheriff’s Department faces class action lawsuit, NBC San Diego News, November 13, 2023

Lawsuit over adverse jail conditions and treatment wins class action status, San Diego Union Tribune, November 12, 2023 

‘There’s really a long, long way to go in that facility’: Lawyer, families discuss San Diego County jail conditions, San Diego Union Tribune, March 20, 2023

‘We’re begging for help’: Jailed people and their families ask court to force immediate change, San Diego Union Tribune, August 11, 2022

Jail reform advocates call on San Diego County to overhaul inmate care policy, NBC San Diego News, August 11, 2022

Jail reform advocates call on San Diego County to address in-custody deaths, CBS8 News, August 11, 2022

Families and activists sue over jail deaths, ABC10 News, August 11, 2022

Jail Reform Advocates Call on San Diego County to Address in-Custody Deaths, Times of San Diego, August 11, 2022

Attorneys seek emergency order to force changes at San Diego County Jail, San Diego Union-Tribune, May 2, 2022

Motion filed urging court to address dangerous conditions at county jails, Fox5 San Diego, May 2, 2022