42 U.S.C. §1983Civil SuitDuty to ActEMSWrongful death

Federal Court Dismisses Claims in Wrongful Death Suit Involving Santa Barbara County

A federal court has dismissed several claims in a wrongful death lawsuit arising from the death of a Santa Barbara County jail inmate who was injured in a traffic crash and later died from a pulmonary embolism. The case, Rodriguez-Gonzalez v. County of Santa Barbara, was decided by U.S. District Judge Otis D. Wright II on October 29, 2025.

The suit was filed by the family of Luis Enrique Duron-Rodriguez, who was pursued by Santa Barbara County Sheriff’s deputies for speeding on August 31, 2023. According to the complaint, Duron-Rodriguez crashed into a parked vehicle and a tree, sustaining head and upper body injuries. The Santa Barbara County Fire Department responded to the scene, but a sheriff’s deputy—identified as John Hartly Freedman—allegedly prevented paramedics from treating or transporting the patient. Instead, Freedman transported Duron-Rodriguez to the hospital in his patrol car.

At the hospital, Dr. Brett Wilson diagnosed facial trauma, internal mouth lacerations, and intoxication but released Duron-Rodriguez to the jail. While in custody, Duron-Rodriguez reportedly exhibited confusion and withdrawal symptoms that were not adequately treated. He was later found unresponsive and pronounced dead on September 3, 2023.

The lawsuit named the County of Santa Barbara, several sheriff’s deputies, and multiple medical providers as defendants, alleging civil rights violations under 42 U.S.C. §1983, negligence, and failure to summon medical care. The Santa Barbara County Fire Department was not named as a defendant.

Judge Wright dismissed the plaintiffs’ claims of deliberate indifference and interference with familial relationship against Deputy Freedman, concluding that his decision to transport Duron-Rodriguez directly to the hospital satisfied his constitutional obligation to provide medical care. The court also dismissed the County’s Monell liability claim for failure to train and unconstitutional policy, finding the allegations too conclusory. The plaintiffs were granted limited leave to amend their Monell claim.

Although the fire department was not a defendant, the case offers some important considerations for fire and EMS agencies that routinely operate alongside law enforcement. The absence of liability does not mean the absence of lessons.

  1. Scene Authority and Medical Control
    The incident highlights the importance of clearly defined authority when both law enforcement and fire/EMS respond to a medical emergency. Fire departments should ensure that policies and memoranda of understanding spell out who maintains authority and responsibility for medical decision-making once patient care begins.
  2. Documentation of Interference
    When another agency prevents EMS personnel from treating or transporting a patient, the incident should be carefully documented. Recording who issued the order, what was said, and when can later prove essential in defending the actions of responders and clarifying the sequence of events.
  3. Duty to Advocate for Patient Care
    Even if physically prevented from acting, paramedics and EMTs should continue to advocate for necessary medical care and notify medical control or dispatch when care is obstructed or delayed. This is essential to avoid allegations that trained medical personnel negligently acquiesced while an untrained law enforcement officer made important medical decisions, or that responders failed to provide information that could have helped the officer make an informed choice. Advocacy must be firm but professional—never escalating into physical or verbal confrontation.
  4. Training for Custody and Arrest Scenarios
    The case underscores the tension that can arise when patient care intersects with law enforcement custody. Joint training can help both groups understand when medical priorities must take precedence over investigative or custody concerns.
  5. County-Level Exposure
    Because the fire department is a county agency, its records and practices can come under scrutiny whenever the county faces litigation. Strong policies, accurate reports, and consistent training are the best protection against being drawn into related claims.

In short, while the Santa Barbara County Fire Department was not accused of wrongdoing, the facts illustrate the importance of maintaining professional independence, documentation discipline, and cooperative protocols in joint response situations.

Attached is a copy of the decision, along with a copy of the original complaint:

Curt Varone

Curt Varone has over 50 years of fire service experience and 40 as a practicing attorney licensed in both Rhode Island and Maine. His background includes 29 years as a career firefighter in Providence (retiring as a Deputy Assistant Chief), as well as volunteer and paid on call experience. Besides his law degree, he has a MS in Forensic Psychology. He is the author of two books: Legal Considerations for Fire and Emergency Services, (2006, 2nd ed. 2011, 3rd ed. 2014, 4th ed. 2022) and Fire Officer's Legal Handbook (2007), and is a contributing editor for Firehouse Magazine writing the Fire Law column.

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