Heriberto Rodriguez v. County of Los Angeles, 891 F.3d 776 (2018)

Citation: Heriberto Rodriguez v. County of Los Angeles, 891 F.3d 776 (2018)
Parent Document: Heriberto Rodriguez v. County of Los Angeles, 891 F.3d 776 (2018)
Jurisdiction: United States (federal)
Effective Date: 2018-05-30
Original Source: https://www.courtlistener.com/opinion/4502306/heriberto-rodriguez-v-county-of... ↗

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Nor does the timing of the op-ed article published in the
Los Angeles Times by S.M.’s mother near the end of the trial
require us to find implied bias. S.M.’s mother’s publicly
expressed opinion on civilian oversight of LASD does not
implicate our case law involving “close relatives of a juror
[that] ‘have been personally involved in a situation, involving
a similar fact pattern,’ ” Fields, 503 F.3d at 773 (quoting
Tinsley, 895 F.2d at 528)), nor does it present a new type of
“extreme” situation giving rise to implied bias. An innocent
explanation for the article’s timing appears in its first two
sentences: “It is time to seriously consider a civilian
oversight board for the Los Angeles County Sheriff’s
Department. The Board of Supervisors is scheduled to
consider such a proposal next week.” (Emphasis added.)
The remainder of the article is devoted largely to the virtues
of civic participation. The article alludes to problems in Los
Angeles’s jails only in general terms and does not mention
                     RODRIGUEZ V. CRUZ                        53

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