## Facts

- Dion Starr, a pretrial detainee in the Los Angeles County Jail, alleged he faced threats from a group of inmates and called for deputy assistance.
- Starr alleged a deputy opened his cell gate to allow the threatening inmates to enter, after which Starr and his cellmate were repeatedly stabbed; Starr alleged he was stabbed twenty-three times.
- Starr alleged that after the attack, while he was seriously injured, a deputy used racist slurs, kicked him repeatedly (fracturing his nose), and interfered with his ability to obtain medical treatment while other deputies watched.
- Starr sued Sheriff Leroy Baca in his individual capacity under 42 U.S.C. § 1983, alleging unconstitutional conditions of confinement and deliberate indifference under the Eighth and Fourteenth Amendments based on supervisory liability.
- The complaint alleged Baca knew of pervasive inmate-on-inmate and deputy-on-inmate violence, serious injuries, and deaths in the jail system through reports, investigations, and other notice, and failed to take adequate corrective action (policy changes, training, supervision, discipline).

## Issues

1. Whether the complaint plausibly stated a § 1983 supervisory-liability claim that Sheriff Baca, through his own acts or omissions, was deliberately indifferent to unconstitutional jail conditions and inmate safety.
2. Whether Ashcroft v. Iqbal foreclosed deliberate-indifference supervisory liability in conditions-of-confinement cases or otherwise required dismissal for inadequate factual pleading.
3. Whether the complaint sufficiently alleged a causal connection between Baca’s conduct and Starr’s injuries to survive a Rule 12(b)(6) motion.

## Decision

- The Ninth Circuit reversed the district court’s Rule 12(b)(6) dismissal of the individual-capacity claim against Baca and remanded for further proceedings.
- The court held the complaint included substantial, nonconclusory factual allegations supporting a plausible inference that Baca was deliberately indifferent to known, widespread violence and misconduct in the jails.
- The court rejected the argument that Iqbal categorically eliminated supervisory liability in deliberate-indifference conditions-of-confinement cases, emphasizing that liability must rest on the supervisor’s own culpable action or inaction.
- The court held the complaint plausibly alleged causation by linking Baca’s alleged awareness of recurring failures (including similar incidents) and persistent inaction to the conditions that enabled the assault on Starr.
- A dissent would have required more particularized allegations that Baca knew of and disregarded the specific risk to Starr.

## Legal Principles

- Section 1983 does not allow respondeat superior; a supervisor is liable only for the supervisor’s own unconstitutional conduct.
- A supervisor may be individually liable where the supervisor’s own culpable action or inaction in training, supervision, or control of subordinates; acquiescence in constitutional violations; or reckless or callous indifference causes a constitutional injury.
- Under Twombly and Iqbal, a complaint must plead sufficient factual matter to state a plausible claim; courts disregard mere conclusory assertions but accept well-pleaded factual allegations as true at the motion-to-dismiss stage.
- Iqbal does not categorically bar deliberate-indifference supervisory claims in conditions-of-confinement cases; it requires factual allegations showing the supervisor’s personal involvement through deliberate indifference and a plausible causal connection to the injury.

## Conclusion

The Ninth Circuit held that detailed allegations of a sheriff’s notice of pervasive jail violence and repeated failures to correct known risks can plausibly state an individual-capacity § 1983 supervisory-liability claim for deliberate indifference to unconstitutional conditions, and it reversed the dismissal because the complaint adequately pleaded personal culpability and causation under Twombly and Iqbal.


Starr v. Baca, 652 F.3d 1202 (9th Cir. 2011)