context: To the extent that Ramirez alleged Fourteenth Amendment substantive due process claims, dismissal was proper because Ramirez failed to allege facts sufficient to show an intent to punish or that the policies were unrelated to a legitimate governmental purpose.
citation_a.signal: see also
citation_a.parenthetical: a pretrial detainee's Eighth Amendment claim is "properly recharacterized ... as a substantive due process claim under the Fourteenth Amendment"
citation_a.sentence: See Bell v. Wolfish, 441 U.S. 520, 535-36, 538, 99 S.Ct. 1861, 60 L.Ed.2d 447 (1979) (setting forth criteria for evaluating a pretrial detainee’s substantive due process claim); see also Byrd v. Maricopa Cnty. Sheriff’s Dep’t, 629 F.3d 1135, 1137 n. 3 (9th Cir.2011) (en bahc) (a pretrial detainee’s Eighth Amendment claim is “properly recharacterized ... as a substantive due process claim under the Fourteenth Amendment”).
citation_b.signal: see
citation_b.parenthetical: setting forth criteria for evaluating a pretrial detainee's substantive due process claim
citation_b.sentence: See Bell v. Wolfish, 441 U.S. 520, 535-36, 538, 99 S.Ct. 1861, 60 L.Ed.2d 447 (1979) (setting forth criteria for evaluating a pretrial detainee’s substantive due process claim); see also Byrd v. Maricopa Cnty. Sheriff’s Dep’t, 629 F.3d 1135, 1137 n. 3 (9th Cir.2011) (en bahc) (a pretrial detainee’s Eighth Amendment claim is “properly recharacterized ... as a substantive due process claim under the Fourteenth Amendment”).