Case Citator › Simmons v. Navajo County, Ariz.

Simmons v. Navajo County, Ariz.

Is it still good law? What later courts have actually done to this case.

Overruled in part
Court
Ninth Circuit
Citation
609 F.3d 1011
Decided
Confirmed treatments
1
Flagged citations read
254 of 254
Citing cases (total)
1,039
Treatment dates
2018
Overruled in part
A reviewed court has overruled part of this case’s holding. Simmons v. Navajo County, Ariz. has been overruled in part on the standard for pretrial detainees' medical-care claims. All 254 flagged citations have been read.
More on how this was screened

Gordon v. County of Orange held that an objective deliberate-indifference standard governs those claims after Kingsley v. Hendrickson and the en banc decision in Castro v. County of Los Angeles, displacing the subjective standard Simmons applied. Simmons's other holdings, including the fair-notice standard for affirmative defenses, were not displaced.

Every treatment on this page is written from the citing opinion itself, with a verbatim quote, never copied from a commercial citator. A citation flagged by our screen but not shown here was read and found not to weaken this case.

1,039 later cases cite Simmons v. Navajo County, Ariz.; 254 of those citations sat close to treatment language and were flagged for reading, and all of them have been read. Citations that did not sit near treatment language were not flagged and were not read one by one, so a court that weakened this case without using any of that language would not appear here.

Relying on Simmons v. Navajo County, Ariz.?

This page shows what later courts did to it. Ask about your specific facts and see whether it still carries your argument, with citations you can check.

Treatments

Overruled in part

  • The Ninth Circuit displaced Simmons's subjective standard for pretrial detainees' medical-care claims with an objective deliberate-indifference standard.

    Gordon v. County of Orange · Ninth Circuit · filed

    Thus, prior to our decision in Castro, all conditions of confinement claims, including claims for inadequate medical care, were analyzed under a subjective deliberate indifference standard whether brought by a convicted prisoner under the Eighth Amendment or pretrial detainee under the Fourteenth Amendment. ... Third, we have long analyzed claims that government officials failed to address pretrial detainees’ medical needs using the same standard as cases alleging that officials failed to protect pretrial detainees in some other way. 3 Simmons v. Navajo Cty., Ariz., 609 F.3d 1011, 1017–18 (9th Cir. 2010); ... Accordingly, we hold that claims for violations of the right to adequate medical care “brought by pretrial detainees against individual defendants under the Fourteenth Amendment” must be evaluated under an objective deliberate indifference standard.
    Read the full opinion on CourtListener →

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