PHOENIX (LN) — A federal judge in Arizona on Tuesday denied motions to dismiss filed by the Yuma County Board of Supervisors while simultaneously dismissing all Section 1983 claims against the private behavioral health company and its staff who carried out Megan Castillo's 2024 civil commitment, concluding that Community Bridge, Inc. and its employees failed to clear the state-action bar required to face constitutional liability.
According to the Second Amended Complaint, Castillo's daughter went to Community Bridge, met with an admission coordinator, and with that coordinator's help obtained and filled out an application that was then used to have Castillo apprehended by Yuma police officers, transported to the facility, and subjected to involuntary assessments over several days before her release on March 2, 2024.
The Second Amended Complaint names seven defendants: the Board; Community Bridge and its president and CEO John Hogeboom; Medical Director Jon Caldwell, an independent contractor who allegedly signed the petition for court-ordered evaluation; Admitting Officer Jonquil Michael, an independent contractor who allegedly authorized the apprehension order; Admission Coordinator Africa Carrasco, who the complaint alleges prepared the petition by cutting and pasting from the original application; and behavioral health evaluator Jennifer Andjelich.
The court dismissed all Section 1983 claims against the private defendants with prejudice, concluding that the complaint failed to plausibly allege that Community Bridge or any of its staff acted under color of state law. Drawing on the Ninth Circuit's 2020 decision in Rawson v. Recovery Innovations, the court examined factors including state involvement in decisionmaking, state authorization, whether state protocols affirmatively commanded the conduct, and the state's civil commitment powers, and concluded this case came up short on nearly every one.
The most significant gap was state involvement. Unlike in Rawson, where a county prosecutor communicated extensively with the private facility about discharge possibilities, treatment methods, and trial strategy during a 55-day commitment, no county attorney or other state actor is alleged to have been heavily involved in the decisions surrounding Castillo's detention. A private citizen — Castillo's daughter — initiated the process, private medical professionals evaluated Castillo, and those same professionals petitioned the state court for further evaluation. The court concluded that police transporting Castillo to the facility, and a state court approving the petition, provided only slight support for state action and fell well short of the entwinement present in Rawson.
The court also rejected Castillo's argument that the county's contract with Community Bridge — under which the company agreed, according to the complaint, to act jointly and cooperatively in developing and implementing a unified, cohesive and well-integrated system of mental health services in Yuma County and was paid $1.3 million annually — was enough to establish a symbiotic relationship. Citing Supreme Court precedent, the court noted that acts of private contractors do not become acts of the government by reason of their significant or even total engagement in performing public contracts, and that the collaboration between Community Bridge and the county was mostly unrelated to Castillo's specific commitment.
On the Monell claims, the court dismissed the claim against Community Bridge because it is not a state actor, and noted that Hogeboom — sued in his individual capacity despite not personally participating in Castillo's commitment — appeared to be the target of a Monell theory that can only be brought against an official-capacity defendant.
The Board's motion to dismiss was denied, allowing Castillo's Fourth and Fourteenth Amendment claims and the familial-association claims brought by Castillo and her husband Scott to proceed against the county entity.
The dismissal of the private defendants was with prejudice. The court noted that dismissal with prejudice was appropriate given the plaintiffs' repeated inability to plausibly plead state action across multiple rounds of pleading. The case had previously resulted in an October 2025 order that partially dismissed Section 1983 claims against two defendants — Andjelich and Michael — for failure to adequately allege state action, prompting the filing of the Second Amended Complaint that, as the court put it, stirred up the proverbial hornet's nest, with each defendant separately moving to dismiss.
Castillo was evaluated for four days and released without being ordered into involuntary treatment — a fact the court noted distinguished her case from Rawson's plaintiff, who was involuntarily committed for fifty-five days and received extensive treatment, circumstances the Ninth Circuit concluded weighed heavily in favor of state action.