Plaintiff's separate challenge to a jury instruction requiring deference to jail's policies sufficiently preserved a more general challenge to the instruction.
Juries should be instructed to give deference to jail's policies only where the treatment is a necessary, justified, and proportional security-based policy.
Absent any security-based reason, deference to the policy should be denied as a matter of law.
Pretrial detainees are entitled to a grievance procedure upon changes in their classification that increases the severity of the conditions of confinement.
Deliberate indifference claims arising from medical treatment should be judged under a standard of objective deliberate indifference.
http://cdn.ca9.uscourts.gov/datastore/opinions/2018/07/16/16-56051.pdf