Tracy Alves v. County of Riverside
Explore the Ninth Circuit case Alves v. County of Riverside, where deputies were cleared of excessive force but found negligent for failing to provide medical care after a prone restraint. Learn how this case impacts law enforcement use-of-force standards, civil rights litigation, and police duty of care under California law.
6/22/20251 min read
On July 29, 2019, Riverside County deputies responded to multiple 911 calls about a shirtless man in pajama pants acting erratically and bleeding from the head. Minutes later, that man—Kevin Niedzialek—was restrained, handcuffed, and placed in a prone position. He died the next day.
What followed was a lawsuit under 42 U.S.C. § 1983 brought by his successor-in-interest, Tracy Alves, alleging both excessive force and deliberate indifference to medical needs. While the jury rejected the excessive force claim, they found the deputies negligent for failing to monitor Niedzialek’s condition and provide timely medical aid. A $7.5 million verdict was ultimately reduced based on comparative fault.
But here’s the legal twist: the jury’s findings may seem inconsistent—no excessive force, yet liability for negligence. The Ninth Circuit upheld the verdict, explaining that California’s negligence standard is broader than Fourth Amendment reasonableness.
👉 So how should law enforcement interpret this ruling?
👉 What does this mean for prone restraints, officer training, and post-arrest care?
🎥 I break it all down in this episode of Ten on Tactics. Watch the full legal analysis and tactical review here:
Watch the full video on YouTube →
