The U.S. Court of Appeals for the Ninth Circuit has affirmed a jury verdict that found Graham County Sheriff PJ Allred not liable for the death of a woman who died while in county custody. The unpublished memorandum decision, filed Jan. 20, 2026, resolves an appeal brought by Deborah Sanchez, the mother of the deceased woman, Jorden Simms.
Simms died from injuries she sustained when she jumped from a moving transport vehicle while in the custody of the Graham County Sheriff's Office. The case, *Sanchez v. County of Graham* (No. 24-1675), originated in the U.S. District Court for the District of Arizona under Judge John Charles Hinderaker.
The three-judge panel, consisting of Circuit Judges Bennett, Bade, and Sung, unanimously concluded the case was suitable for decision without oral argument. The court assumed the parties' familiarity with the facts and recited them only as necessary for the legal analysis.
Sanchez's primary argument on appeal centered on alleged errors in the district court's final jury instructions and verdict form. She contended that the trial court erred by issuing instructions and a verdict form that referred only to Sheriff Allred rather than to the individual officers who transported Simms. According to Sanchez, this created confusion for the jury because multiple defendants were involved in the case.
The lawsuit named several defendants, including the County of Graham as a government entity, Sheriff PJ Allred in his official capacity, Arthur Perez Jr. and an unknown spouse identified as Jane Doe, Rosemary Juarez-Lacey and an unknown spouse identified as John Doe, and the Graham County Sheriff's Office as a government entity.
During the trial proceedings, the defendants moved for certain relief, though the specific nature of their motions was not detailed in the appeals court's brief memorandum. The district court ultimately provided jury instructions that focused on Sheriff Allred's liability rather than addressing the individual officers involved in Simms' transport.
The Ninth Circuit's decision to affirm the lower court's judgment suggests the appeals court found no reversible error in the jury instruction process. The court's jurisdiction to hear the appeal was established under 28 U.S.C. § 1291, which provides federal appellate courts with jurisdiction over final decisions of district courts.
The case represents another example of the challenges faced by families seeking accountability in custody death cases. Civil rights lawsuits against law enforcement agencies and officials often involve complex questions about individual versus institutional liability, qualified immunity, and the specific circumstances surrounding deaths in custody.
The appeals court's decision was issued as an unpublished memorandum, meaning it carries no precedential value under Ninth Circuit Rule 36-3. This designation is typically reserved for cases that do not establish new legal principles or significantly clarify existing law.
The tragic circumstances underlying the case highlight ongoing concerns about prisoner transport safety and the duty of care owed to individuals in law enforcement custody. When Simms jumped from the moving transport vehicle, she sustained fatal injuries that led to her death, prompting her mother's federal civil rights lawsuit.
Sanchez's appeal strategy focused on procedural challenges to the trial court's handling of the case rather than disputing the underlying facts about her daughter's death. By arguing that the jury instructions were confusing and improperly limited to Sheriff Allred rather than including the individual transport officers, she sought to demonstrate that the jury was not properly equipped to assess liability among the various defendants.
The Ninth Circuit's affirmance of the jury verdict means that Sheriff Allred and the other defendants will not face liability for Simms' death. The decision closes this particular avenue of legal recourse for Sanchez, though the unpublished nature of the memorandum means it will not serve as binding precedent for future similar cases.
Custody death cases often involve detailed factual investigations into the circumstances leading to the death, the adequacy of medical care provided, and whether proper procedures were followed. While the appeals court did not detail the specific evidence presented at trial, the jury's verdict suggests they found insufficient evidence to hold the defendants liable under the applicable legal standards.
The case was submitted to the Ninth Circuit panel on Jan. 23, 2026, just three days after the decision was filed, indicating the court moved quickly to resolve the appeal. The expedited timeline and decision to forgo oral argument suggest the legal issues were relatively straightforward from the appeals court's perspective.
For families facing similar tragedies, the case underscores the importance of careful trial strategy and the challenges inherent in proving liability in custody death cases. The technical nature of Sanchez's appellate arguments also illustrates how procedural issues can become critical factors in determining the outcome of civil rights litigation.