Claims Against the County Strengthened
The panel also reinstated older claims, finding St. Clair plausibly alleged that her addiction, Holloway’s power as an officer, and fear of legal jeopardy delayed her recognition of the abuse.
St. Clair said Holloway pressured her into sex at least 20 times between 2014 and 2021, often using texts and video calls. She alleged she could not refuse because he had arrested her before, knew about her drug use, and claimed knowledge of uncharged crimes.
Her complaint also alleged that her uncle reported the misconduct as early as 2014, yet the county merely warned Holloway without ensuring compliance. The Ninth Circuit noted that a 2019 audit flagged systemic failures in handling complaints, strengthening the claim of county indifference.
“It was an abuse of discretion to dismiss this claim without leave to amend,” McKeown wrote, allowing St. Clair to refine her allegations.
A Broader Pattern of Neglect
According to the opinion, the sheriff’s office allegedly ignored not only Holloway’s conduct but also misconduct by three other deputies. This, the court said, “alleges a cognizable pattern” of failing to address sexual misconduct within the department.
Attorney Tyler Hotchkiss, representing St. Clair, called the ruling “a decision beneficial to both Ms. St. Clair and similarly situated vulnerable women.”
