On January 23, 2020, the Ninth Circuit Court of Appeals affirmed dismissal of a 42 U.S.C. § 1983 Fourteenth Amendment claim against the County of Los Angeles in Sakamoto, et al. v. County of Los Angeles. In this case, an elderly man was arrested for suspicion of driving under the influence and detained for approximately 12 hours in the County jail before being released with a citation. His family members filed suit, alleging failure to protect, after the man failed to return home and was subsequently found dead not far from the jail. After obtaining voluntary dismissals of several state law claims and judgment on the pleadings for the remaining state law wrongful death claim, Emily Suhr and Raymond Sakai successfully obtained summary judgment as to the sole remaining Section 1983 claim by demonstrating that the County had no notice that the man would be unable to care for himself if released. In affirming the decision, the Ninth Circuit reiterated that no County employee acted with deliberate indifference to a known or obvious danger, precluding liability against the County.