Case Explained: ALSTON V. COUNTY OF SACRAMENTO, ET AL.

Court: United States Court of Appeals for the Ninth Circuit Filed: 2026-08-04 Docket: 2:18-cv-02420-TLN-CKD The ninth-circuit affirmed the district court’s grant of summary judgment in favor of the County of Sacramento and its deputies on plaintiff Eric Anthony Alston, Jr.’s civil rights and state-law claims arising from his November 2017 arrest and transport. The court held that no reasonable jury could find Deputy Ball’s driving constituted excessive force under the Fourth Amendment, as in-car camera footage contradicted Alston’s account of striking his head on a partition and showed he shifted forward voluntarily; applying *Graham v. Connor*, the court found the intrusion minimal compared to governmental interests. The court further ruled that the deputies did not act with deliberate indifference under the Fourteenth Amendment because they observed Alston descend stairs and walk unassisted before instructing him into the patrol car, meaning there was no substantial risk of serious harm that a reasonable officer would have appreciated. Additionally, the court affirmed summary judgment on state-law negligence claims, finding no evidence that it was foreseeable the deputies’ instructions would cause Alston to fall while wearing a walking boot and handcuffs. Consequently, the court determined that Alston’s Bane Act claim necessarily failed due to the absence of an underlying constitutional violation, and the County could not be held liable under 42 U.S.C. § 1983. The judgment is affirmed. Do It For The Case Law is a news reporting service. Nothing in this episode constitutes legal advice.