After a federal judge dismissed Anna Sandoval’s lawsuit over her husband’s death in a San Diego jail, she faced a choice: walk away or keep fighting. The ruling came nearly two years after she filed her lawsuit arguing three jail nurses had violated her husband Ronnie’s constitutional rights b y failing to respond to obvious signs of medical distress. And it came four years after his death at 46. Appeals in federal civil rights cases can take years and rarely succeed. “I wasn’t going to give up,” Sandoval said. “I wanted them to be accountable.” Five years ago this month, the 9th U.S. Circuit Court of Appeals reversed the district court’s ruling and revived the case. But the judges also published the opinion — a step taken in only about 8% of appeals. That made the ruling binding precedent, meaning other federal courts in the western United States must follow it when evaluating similar jail medical-care cases. “Sandoval broke barriers for the civil rights community regarding inadequate medical care claims,” said Danielle Pena, one of Anna Sandoval’s attorneys. “In every one of my cases, judges cite Sandoval as the standard.” In the years since it was published, Sandoval v. County of San Diego has been cited often in jail-death litigation and routinely invoked by plaintiffs and judges in cases involving claims of delayed or inadequate medical care. “Before Sandoval, defendants would argue that even obvious failures weren’t clearly unconstitutional. Sandoval changed that,” said Denisse Gastélum, a civil rights attorney who has cited the ruling in jail death and suicide cases. Understanding why the ruling was so significant takes a little unpacking. Ronnie Sandoval died on Feb. 23, 2014, roughly five hours after he was booked into the San Diego Central Jail following an arrest for methamphetamine possession. Ronnie Sandoval, 46, died in San Diego County sheriff’s custody in 2014, just hours after his arrest. (Sandoval family) During booking, a deputy noticed Sandoval was sweating profusely, appeared lethargic and was struggling to answer questions. The deputy asked a nurse to evaluate him, unaware that he’d swallowed a large amount of methamphetamine before his arrest. The nurse performed only a brief blood-sugar check, which came back normal. An hour later, a second deputy observed that Sandoval “was still sweating a lot and appeared to be very tired and disoriented,” according to court records. That deputy took Sandoval to nurse Romeo DeGuzman, telling DeGuzman “there [is] still something going on … so you need to look at him more thoroughly.” DeGuzman told the deputy to put Sandoval in a medical observation cell and performed another blood sugar test, which came back normal. After that, DeGuzman didn’t check on Sandoval for the remaining six hours of his shift — even though the cell was just 20 feet away from the nurses’ station — and did not pass along any information about Sandoval to the staff on the next shift. Close to 1 a.m., a deputy witnessed Sandoval suffer a seizure and requested emergency medical help. The nurse in charge initially refused instructions from two nurses and a deputy to call 911, then summoned EMTs who determined Sandoval’s condition was too serious for them to handle. The nurse eventually called paramedics who arrived at 1:42 a.m., roughly 47 minutes after Sandoval was first seen having a seizure. At that point, he still had a pulse, but he lost it when he was transferred to a gurney. Ronnie Sandoval was pronounced dead at 2:11 a.m. "I feel like Ronnie got a little bit of justice, and other people don’t have to go through what I went through,” Anna Sandoval says of her lawsuit over her late husband's death in jail. (Nelvin C. Cepeda / The San Diego Union-Tribune) By the time Anna Sandoval’s case reached the Ninth Circuit, legal rules governing medical care in jails were already established. What was less clear was how judges were supposed to apply them. In theory, courts were supposed to ask whether a reasonable doctor or nurse would have recognized a medical emergency. In practice, cases were often dismissed because judges felt there wasn’t a similar prior example to rely on. It’s a legal principle known as qualified immunity: A person is shielded from liability unless prior court decisions had already made it clear that their conduct was illegal. In its ruling, the 9th Circuit said courts shouldn’t get sidetracked by minor factual differences between cases. Instead, judges should focus on practical questions: Was the person in obvious medical distress? Did staff have the time and opportunity to respond? Did they fail to take reasonable steps? “To be sure,” the court wrote, “we have never before addressed the specific factual circumstances here, where a nurse is told that a patient is sweating, disoriented, and in need of a more thorough look but does nothing more than perform a quick 10-second blood test. But [the nurse] is not entitled to qualified immunity simply because ‘the very action in question has [not] previously been held unlawful.’” The impact was clear for lawyers representing other families. “What Sandoval did was give courts something concrete to work with,” Pena said. “It put real-world facts around a legal standard that had been abstract.” Ronnie Sandoval, 46, died in San Diego County sheriff’s custody in 2014, just hours after his arrest. (Sandoval family) Even though details may vary, the medical lapses spelled out in Anna Sandoval’s lawsuit mirror those in many jail deaths: warning signs that go unheeded and a failure to quickly summon help. Civil rights attorney Tim Scott said Sandoval built on earlier 9th Circuit rulings by clarifying that pretrial detainees don’t have to prove jail staff intended to violate their rights — they only need to show that officials knew or should have known they were failing to provide medical care. “Medical deaths tend to be caused by institutional inattention and apathy, rather than subjective animus,” Scott said. After the 9th Circuit reversed its dismissal, the case returned to federal court. Pena said the county pressed for a settlement but appeared to assume Anna Sandoval would accept a low offer rather than endure a trial. The case went to trial in April 2024. Jurors found the county liable but also concluded that Ronnie Sandoval bore some responsibility for his own death because he had failed to tell deputies or medical staff that he had ingested methamphetamine before his arrest. The jury calculated the amount of damages at $3.6 million — $2.75 million for the death and $850,000 for the mental, physical and emotional pain Anna Sandoval experienced — but cut the amount in half based on what they found was shared liability for his death. The county threatened to appeal the verdict but ultimately agreed to a settlement that included fees for Sandoval’s attorneys. Pena said she couldn’t discuss the settlement. But public records show a payment of $3 million to the estate of Ronnie Sandoval on Sept. 5, 2025. Anna Sandoval said she’s heard from other families and advocates who have told her how the 9th Circuit ruling is being used in other cases. “Knowing that this case has helped other people and made it easier for them to fight for their loved ones, it makes you feel really good,” she said. “I feel like Ronnie got a little bit of justice, and other people don’t have to go through what I went through,” she added. Sandoval described her husband as a generous, caring person who looked after friends and family and took pride in helping others. She acknowledged he had a drug problem but rejects any suggestion it should excuse inaction by medical staff. “People mean something — they have a worth,” she said, “maybe not to you, but to somebody else. You don’t have to love them, but you have to treat them like a person.” ...read more read less