Vaughn, Jr. v. Klamath County Fire District1 — 9th Cir. (argued August 6, 2026)
The U.S. Court of Appeals for the Ninth Circuit hears oral argument in Vaughn, Junior v. Klamath County Fire District Number One. The case arises from a Section 1983 lawsuit brought on behalf of the estate of Teresa Vaughn. By the district court's account of the evidence, Vaughn had tested positive for COVID-nineteen five days earlier, and on the morning of December twenty-sixth, two thousand twenty, her domestic partner called nine one one because Vaughn had woken up struggling to breathe. Two of the fire district's paramedics responded. They did not take her to the hospital. One of them asked her partner to drive her there in her own car, and cancelled a fire engine that was on its way with a defibrillator and three more senior paramedics. About three tenths of a mile down the road, Vaughn suffered a cardiac event. She was revived at the emergency room but could not be kept alive without a ventilator, and her family made the decision to end life support. The family's claim is that the paramedics' own actions left her in worse danger than if no one had come at all. The paramedics dispute the family's account of how she appeared that morning. The Section 1983 claim went to trial against two of the district's paramedics, sued as individuals. The fire district itself faced only state-law claims; a public body cannot claim qualified immunity at all. Three times the two paramedics asked to be let out of the case on qualified immunity: first on a motion to dismiss, then on summary judgment, and finally, at trial, on a Rule 50A motion for judgment as a matter of law. Each time the district court refused, finding disputed facts about whether they had violated Vaughn's constitutional rights. Counsel for the defense tells the panel that the court also ruled, as a matter of law and on all three occasions, that the claimed right was clearly established. Counsel for the estate reads those same rulings differently, saying the disputed facts bore on the clearly-established question too. The defendants did not appeal that summary judgment denial, and the panel returns to that point repeatedly: a denial resting on a purely legal ruling of this kind would likely have been appealable right away, and counsel for the defense told the court he does not know why no appeal was taken. What the defendants did appeal was the Rule 50A denial. After that ruling the trial ran to completion. All the evidence came in, the case went to the jury, the jury could not reach a verdict, and the district court declared a mistrial. A retrial is expected. The defendants also filed a renewed motion under Rule 50B, which the district court denied as well, but that denial was never separately appealed either. The core legal issue before the panel is whether the Ninth Circuit has jurisdiction to hear an interlocutory appeal from the denial of a Rule 50A motion based on qualified immunity, or whether that ruling can be reviewed only after a final judgment, or through an appeal from the Rule 50B denial. The question is procedurally unusual, with no controlling precedent squarely on point.
Vaughn, Jr. v. Klamath County Fire District1 (No. 25-4210) — U.S. Court of Appeals for the Ninth Circuit, argued August 6, 2026.
- 0:00Introduction
- 3:28advocate_intro
- 4:08Section 1983
- 5:03State-created danger doctrine
- 6:08Qualified immunity
- 7:09Rule 50A motion
- 8:33Collateral order doctrine
- 26:29advocate_intro
- 34:44advocate_intro
- 37:54outro