The Ninth Circuit Court of Appeals has affirmed a district court's dismissal of civil rights claims in *D.R. v. County of Contra Costa*, a case involving the death of a minor and allegations of constitutional violations by county officials.
The appellate court issued a memorandum opinion on Jan. 20, 2026, addressing multiple claims brought by D.R.'s family members, including her successor in interest John Freeman, John Freeman individually, and Cristina Ramirez. The defendants included Contra Costa County, Tasha Mizel, Marcie Franich, and Brian S. Stern.
The case centered on three primary legal issues that the family appealed to the Ninth Circuit. First, the appellants challenged the district court's dismissal of their Monell claim against Contra Costa County for allegedly seizing D.R. without a warrant. Monell claims allow plaintiffs to hold local governments liable under Section 1983 when constitutional deprivations result from official policies or customs.
Second, the family contested the dismissal of their claim against defendant Tasha Mizel for allegedly failing to protect D.R. This type of claim typically arises under the Due Process Clause when government officials have a special relationship with an individual that creates an affirmative duty to protect.
Third, the appellants challenged the district court's denial of their motion for relief under Federal Rule of Civil Procedure 60(b) regarding the dismissal of their Monell claim. Rule 60(b) allows courts to provide relief from final judgments under specific circumstances, including newly discovered evidence or other reasons justifying relief.
The original case was filed in the U.S. District Court for the Northern District of California under case number 3:19-cv-07152-MMC, with District Judge Maxine M. Chesney presiding. The case was argued and submitted to the Ninth Circuit on Jan. 8, 2026, in San Francisco.
The three-judge panel consisted of Circuit Judges Nguyen and Bennett, along with District Judge Kiyo A. Matsumoto, who sat by designation. The court's decision was issued as a memorandum opinion, which means it is not appropriate for publication and does not serve as precedent except as provided by Ninth Circuit Rule 36-3.
The Ninth Circuit's ruling was mixed, with the court affirming the district court's decisions in part while reversing in part. However, the specific details of which claims were affirmed and which were reversed were not fully detailed in the available portions of the opinion.
The legal framework for Monell claims requires plaintiffs to demonstrate that the alleged constitutional violation resulted from a municipal policy or custom. As the Supreme Court established in *Monell v. Department of Social Services* (1978), local governments cannot be held liable under Section 1983 based solely on respondeat superior liability. Instead, plaintiffs must show that the constitutional deprivation was caused by an official policy, widespread practice, or deliberate indifference by policymaking officials.
Failure to protect claims under Section 1983 typically require plaintiffs to establish that government officials had a special relationship with the victim that created an affirmative constitutional duty to protect. These claims are often difficult to prove because the Due Process Clause generally does not impose affirmative duties on government actors to protect individuals from private violence.
The case appears to involve complex questions about government liability and the constitutional rights of minors in government custody or under government supervision. The allegations suggest that D.R. was seized without a warrant and that officials failed to adequately protect her, ultimately resulting in her death.
Rule 60(b) motions are relatively uncommon and require plaintiffs to demonstrate extraordinary circumstances that justify reopening a final judgment. Courts typically grant such relief only in cases involving fraud, newly discovered evidence, or other compelling reasons that could not have been addressed during the original proceedings.
The mixed outcome suggests that while the appellants succeeded on at least one issue, the majority of the district court's rulings were upheld. This type of partial reversal is not uncommon in complex civil rights cases where multiple legal theories and defendants are involved.
The case highlights ongoing challenges families face when seeking accountability for alleged government misconduct involving minors. Civil rights litigation against government entities requires plaintiffs to overcome significant legal hurdles, including qualified immunity for individual officials and the heightened standards for municipal liability under Monell.
The Ninth Circuit's decision will likely have implications for similar cases in the circuit involving allegations of government misconduct toward minors and the standards for establishing municipal liability under federal civil rights law.