Navarro, Mike v. Jurupa Unified School District Complaint - Oct 10, 2021 - Adamson Ahdoot LLP
Navarro, Mike v. Jurupa Unified School District Complaint – Oct 10, 2021

Update: This case has been resolved. For more information, please visit Cristian Navarro’s case results page.

On October 1, 2020, the Navarro family lost their eldest son Cristian to the reckless disregard for his health and safety displayed by The Jurupa Unified School District, the Patriot High School football team, and its coach Christopher Fowler.

The Navarro family contacted the compassionate wrongful death attorneys at Adamson Ahdoot LLP, to seek justice for their son and brother’s memory. It is an honor to represent the Navarro family, and the below complaint illustrates Adamson Ahdoot LLP’s aggressive pursuit of relief for their emotional well-being.

Full complaint text:

COMES NOW Plaintiffs, MIKE ANGEL NAVARRO and CYNTHIA SALCIDO, individually,
and as successors in interest to CRISTIAN ANGEL NAVARRO, deceased, who allege as follows:
PARTIES
1. At the time of the incident hereinafter alleged, Plaintiff, MIKE ANGEL NAVARRO, was
the father of Decedent, CRISTIAN ANGEL NAVARRO.
2. At the time of the incident hereinafter alleged, Plaintiff, CYNTHIA SALCIDO, was the
mother of Decedent, CRISTIAN ANGEL NAVARRO.
COMPLAINT FOR DAMAGES
3. The true names and/ or capacities, whether individual, corporate, associate, or otherwise,
of Defendants DOES 1 through 100, inclusive, and each of them, are unknown to Plaintiffs, who
therefore, sue said Defendants by such fictitious names pursuant to California Code of civil Procedure
§ 474. Plaintiffs are informed and believe, and upon such information and belief allege, that each of the
Defendants fictitiously named herein as a DOE is legally responsible, negligently or in some other
actionable manner, for the events and happenings hereinafter referenced to, and proximately caused the
damages to Plaintiffs hereinafter alleged. Plaintiffs will seek leave of court to amend this Complaint to
assert the true names and/ or capacities of such fictitiously named Defendants when the same have been
ascertained.
4. Plaintiffs are informed and believe, and thereon allege, that at all times relevant hereto
each of the Defendants, including without limitation the DOE Defendants, was the agent, affiliate,
officer, director, manager, principal, alter-ego, and/or employee of the other Defendants and was at all
times acting within the scope of such agency, affiliation, alter-ego relationship and/ or employment and
actively participated in, or subsequently ratified and adopted, or both, each and all of the acts or conduct
alleged herein, with full knowledge of all the facts and circumstances, including, but not limited to, full
knowledge of each and all of the violations of plaintiff’s rights and the damages to Plaintiffs approximately caused thereby.
5. At the time of the incident hereinafter alleged, Patriot High School was a school in JURUPA UNIFIED SCHOOL DISTRICT.
6. At the time of the incident hereinafter alleged, Defendant, JURUPA UNIFIED SCHOOL DISTRICT, was a government entity conducting operations in the City of Jurupa Valley and County of Riverside, California.
7. At the time and place of the incident hereinafter alleged, Plaintiffs are informed, believe and thereon allege that Defendants, DOES 1 through 50, inclusive, were employees and/or agents of Defendant, JURUPA UNIFIED SCHOOL DISTRICT, and/or Defendants DOES 1 through 50, inclusive, and were acting within the course and scope of their employment and/or agency statuses.
8. At the time and place of the incident hereinafter alleged, Plaintiffs are informed, believe and thereon allege that Defendant, CHRISTOPHER FOWLER, was the Athletic Director, as well as the Head Football Coach, at Patriot High School.
9. At the time and place of the incident hereinafter alleged, Plaintiffs are informed, believe and thereon allege that Defendants DOES 51 through 100 were agents, coaches and/or instructors of the Patriot High School football team, Defendant, JURUPA UNIFIED SCHOOL DISTRICT, and/ or defendants, Does 51 through 100, and were acting within the course and scope of their agency, employment and/or retention.
10. On or about October 21, 2020 prior to the filing of this Complaint, and pursuant to the provisions of Government Code § 910, et seq., Plaintiffs timely, properly, and duly submitted to Defendant, JURUPA UNIFIED SCHOOL DISTRICT, a claim for the injuries and damages set forth herein on account of the events described herein. Plaintiffs’ claim was rejected by Defendant, JURUPA UNIFIED SCHOOL DISTRICT, on November 2, 2020.
GENERAL ALLEGATIONS
11. Prior to the time of the incident hereinafter alleged, Decedent, CRISTIAN ANGEL NAVARRO, was a student at Patriot High School in the City of Jurupa Valley, California.
12. Prior to the time of the incident hereinafter alleged, Decedent, CRISTIAN ANGEL NAVARRO, was a participant on the football team at Patriot High School.
13. Defendants, including but not limited to Defendant, CHRISTOPHER FOWLER, and DOES 51 through 100, inclusive, were Decedent, CRISTIAN ANGEL NAVARRO’ s coaches, trainers, and/or instructors on the Patriot High School football team.
14. At the time of incident hereinafter alleged, Defendants, and each them, were responsible for the safety and well-being of the students of Patriot High School.
15. At the time of incident hereinafter alleged, Defendants were responsible for the safety and well-being of the students of Patriot High School who participated on the school’s football team.
16. On September 28, 2020, Decedent, CRISTIAN ANGEL NAVARRO, was participating in the season’s first practice of the Patriot High School football team.
17. On September 28, 2020, Defendants, and each of them, failed to adequately monitor the students participating in the season s first practice of the Patriot High School football team, including Decedent, CRISTIAN ANGEL NAVARRO, with respect to the potential risk for dehydration and Exertional Heat Stroke due to the physical exertion of the students combined with extremely hot temperatures on that day.
18. On September 28, 2020, Decedent, CRISTIAN ANGEL NAVARRO, exhibited the signs and symptoms of Exertional Heat Stroke, that he was dehydrated, and needed to cool off and rehydrate.
19. On September 28, 2020, Defendants, and each of them, failed to recognize the signs and symptoms of Exertional Heat Stroke that Decedent, CRISTIAN ANGEL NAVARRO, was exhibiting.
20. On September 28, 2020, Defendants, and each of them, failed to provide the students participating in the first practice of the Patriot High School football team, including Decedent, CRISTIAN ANGEL NAVARRO, an opportunity to cool down and/ or rehydrate their bodies.
21. On September 28, 2020, Defendants, and each of them, failed to provide the students participating in the first practice of the Patriot High School football team, including Decedent, CRISTIAN ANGEL NAVARRO, with adequate opportunities and resources, to rest, hydrate, and cool off during the season’s first football practice.
22. At approximately 4: 45 p.m., on September 28, 2020, the temperature in the City of Jurupa
Valley was approximately 104 degrees Fahrenheit.
23. At approximately 4:45 p.m., on September 28, 2020, Decedent, CRISTIAN ANGEL NAVARRO, began to experience the signs and symptoms of Exertional Heat Stroke including disorientation, imbalance, and cognitive problems, eventually collapsing during the Patriot High School football practice as the result of dehydration and the effects thereof, following physical exertion in extremely hot weather.
24. Decedent, CRISTIAN ANGEL NAVARRO, died on October 1, 2020, at approximately 11: 00 a.m., from the injuries caused by Defendants’ and each of their acts and/or omissions on September 28, 2020.
FIRST CAUSE OF ACTION
Negligence— Wrongful Death Against all Defendants)
25. Plaintiffs repeat and reallege the allegations contained in Paragraphs 1 through 24, hereinabove, and incorporate the same as though fully set forth herein.
26. Defendants, JURUPA UNIFIED SCHOOL DISTRICT, and DOES 1 through 50, inclusive, and each of them, hired or otherwise retained the coaches and instructors of the Patriot High School football team, including, but not limited to, Defendant, CHRISTOPHER FOWLER, and DOES 51 through 100, inclusive.
27. The coaches and instructors of the Patriot High School football team, including, but not limited to, Defendant, CHRISTOPHER FOWLER, and DOES 51 through 100, inclusive, were unfit or incompetent to perform the work for which they were hired or otherwise retained.
28. Defendants, JURUPA UNIFIED SCHOOL DISTRICT, and DOES 1 through 50, inclusive, and each of them, knew or should have known, that the coaches and instructors of the Patriot High School football team, including, but not limited to, Defendant, CHRISTOPHER FOWLER, and DOES 51 through 100, inclusive, were unfit or incompetent and that this unfitness or incompetence created a particular risk to students participating in the season’s first practice of the Patriot High School football team, including Decedent, CRISTIAN ANGEL NAVARRO.
29. Prior to, and at approximately 4:45 p.m. on September 28, 2020, Defendants, JURUPA UNIFIED SCHOOL DISTRICT, and DOES 1 through 50, inclusive, and each of them, were negligent in that they failed to ensure that those adults working directly with students at Patriot High School, including, Decedent, CRISTIAN ANGEL NAVARRO, have the knowledge and ability to minimize risks and reduce injuries for the students they serve.
30. In the days prior to, and at approximately 4:45 p.m. on September 28, 2020, Defendants, and each of them, including Defendant, CHRISTOPHER FOWLER and the other coaches and instructors of the Patriot High School football team, failed to appreciate the extremely high temperatures that were prevalent in the City of Jurupa Valley by scheduling the season’s football practice and conditioning drills during the hottest part of the day( 3pm- 5pm), while failing to implement acclimation guidelines for the season’s first day of football practice to allow football players to slowly adjust to the intensity of the practices, and failed to ensure that proper medical coverage was provided and that all football coaches and instructors were familiar with Exertional Heat Stroke policies.
31. Prior to, and at approximately 4:45 p.m. on September 28, 2020, Defendants, and each of them, including Defendant, CHRISTOPHER FOWLER and the other coaches and instructors of the Patriot High School football team, failed to recognize the signs and symptoms of Exertional Heat Stroke including, but not limited to: altered consciousness, disorientation or dizziness, headache, confusion or
a look of being” out of it”, nausea or vomiting, diarrhea, muscle cramps, loss of muscle function/ balance,
inability to walk, collapse, staggering or sluggish feeling, profuse sweating, decreasing performance or
weakness, dehydration, dry mouth, thirst, rapid pulse, low blood pressure, rapid breathing, and irrational
behavior.
32. Prior to, and at approximately 4:45 p.m. on September 28, 2020, Defendants, and each of them, including Defendant, CHRISTOPHER FOWLER and the other coaches and instructors of the Patriot High School football team, were negligent in that they failed to implement an Emergency Action Plan to respond to football players, such as Decedent, CRISTIAN ANGEL NAVARRO, who exhibited the signs and symptoms of Exertional Heat Stroke.
33. Prior to, and at approximately 4: 45 p.m. on September 28, 2020, Defendants, and each of them, including Defendant, CHRISTOPHER FOWLER and the other coaches and instructors of the Patriot High School football team, were negligent in that they failed to ensure proper body cooling methods were available to the football players such as Decedent, CRISTIAN ANGEL NAVARRO, including, but not limited to; a cold-water immersion tub, ice towels, access to water, ice, Temperature (WBGT) Device, rectal thermometer, lubricating gel, and a tent for shade, and likwise ensure that this equipment was prepared before the football practice on September 28, 2020 began.
34. Prior to, and at approximately 4: 45 p.m. on September 28, 2020, Defendants, and each of them, including Defendant, CHRISTOPHER FOWLER and the other coaches and instructors of the Patriot High School football team, were negligent in that they failed to establish guidelines for football players practicing in hot, humid weather including; requiring Wet Bulb Globe Temperature( WBGT) readings and consideration of time of activity, intensity/ duration, equipment issues, and rest/water breaks.
35. At approximately 4:45 p.m. on September 28, 2020, Defendants, and each of them, including Defendant, CHRISTOPHER FOWLER and the other coaches and instructors of the Patriot High School football team were negligent in that they failed to initiate the emergency treatment of Decedent, CRISTIAN ANGEL NAVARRO, who was exhibiting the signs and symptoms of Exertional Heat Stroke.
36. The coaches and instructors of the Patriot High School football team, including but not limited to Defendant, CHRISTOPHER FOWLER, and DOES 51 through 100, inclusive, harmed Decedent, CRISTIAN ANGEL NAVARRO, and thus Plaintiffs.
37. Defendants, JURUPA UNIFIED SCHOOL DISTRICT, and DOES 1 through 50, inclusive, and each of their negligence in hiring, retaining, supervising, educating, and failing to adequately equip the coaches and instructors of the Patriot High School football team, including, but not limited to, Defendant, CHRISTOPHER FOWLER, and DOES 51 through 100, inclusive, was a substantial factor in causing Plaintiffs’ harm.
38. Prior to, and at approximately 4:45 p.m. on September 28, 2020, Defendants engaged in conduct that was so reckless that it was totally outside the range of the ordinary activity involved in high school football.
39. The failure of Defendants, and each of them, to provide adequate opportunities and resources to the students participating in the first practice of the Patriot High School football team, including Decedent, CRISTIAN ANGEL NAVARRO, to rest, hydrate, and cool-off during the practice was entirely outside the range of ordinary activity involved in high school football because providing adequate opportunities and resources to rest, hydrate, and cool-off could have occurred without discouraging vigorous participation or fundamentally changing the activity.
40. Decedent CRISTIAN ANGEL NAVARRO’ s dehydration and the effects thereof, including but not limited to high body temperature and exhaustion, was entirely outside the range of ordinary activity involved in high school football because it could have been prevented without discouraging vigorous participation or otherwise fundamentally changing the activity of participating in the activity.
41. Prior to, and at approximately 4:45 p.m. on September 28, 2020, Defendants, and each of them, acted recklessly in that their conduct was entirely outside the range of ordinary activity involved in teaching or coaching high school football in which Decedent, CRISTIAN ANGEL NAVARRO, was participating on September 28, 2020.
42. Prior to, and at approximately 4:45 p.m. on September 28, 2020, Defendants, and each of them, engaged in conduct totally outside the range of the ordinary activity involved in teaching or coaching high school football.
43. Prior to, and at approximately 4 :45 p.m. on September 28, 2020, Defendants, and each of their failure to use ordinary care increased the risk of injury to Decedent, CRISTIAN ANGEL NAVARRO.
44. Prior to, and at approximately 4:45 p.m. on September 28, 2020, Defendants, and each of them, unreasonably increased the risks to Decedent, CRISTIAN ANGEL NAVARRO, over and above
those inherent in high school football.
45. Prior to, and at approximately 4:45 p.m. on September 28, 2020, Defendants, and each of them, negligently designed, operated, and/or facilitated the football practice at Patriot High School.
46. Prior to, and at approximately 5: 04 p.m. on September 28, 2020, Defendants knew or should have known that their failure to provide adequate opportunities and resources to the students participating in the football practice, including Decedent, CRISTIAN ANGEL NAVARRO, to rest, hydrate, and cool off during the practice could result in harm to the students, including Decedent, CRISTIAN ANGEL NAVARRO.
47. At all times mentioned herein, Defendants’ acts and/or omissions were a substantial factor in causing Decedent CRISTIAN ANGEL NAVARRO’ s death.
48. At all times mentioned herein, Defendants’ acts and/ or omissions were a substantial factor in causing Plaintiffs’ harm.
49. As a direct and proximate result of Defendants’ negligence, Plaintiff, CYNTHIA SALCIDO, has and will in the future suffer economic damages, including but not limited to the loss of the financial support that Decedent, CRISTIAN ANGEL NAVARRO, would have contributed to the family, gifts or benefits that Plaintiff, CYNTHIA SALCIDO, would have expected to receive from Decedent CRISTIAN ANGEL NAVARRO, funeral and burial expenses, and the reasonable value of household services that Decedent, CRISTIAN ANGEL NAVARRO, would have provided. Plaintiff, CYNTHIA SALCIDO, has and will continue to suffer the loss of Decedent, CRISTIAN ANGEL NAVARRO’ s love, companionship, comfort, assistance, protection, affection, society, moral support, and training and guidance. Plaintiff, CYNTHIA SALCIDO’ s damages exceed the minimum jurisdiction of this Court.
50. As a direct and proximate result of Defendants’ negligence, Plaintiff, MIKE ANGEL NAVARRO, has and will in the future suffer economic damages, including but not limited to the loss of the financial support that Decedent, CRISTIAN ANGEL NAVARRO, would have contributed to the family, gifts or benefits that Plaintiff, MIKE ANGEL NAVARRO, would have expected to receive from Decedent, CRISTIAN ANGEL NAVARRO, funeral and burial expenses, and the reasonable value of household services that Decedent, CRISTIAN ANGEL NAVARRO, would have provided. Plaintiff, MIKE ANGEL NAVARRO, has and will continue to suffer the loss of Decedent, CRISTIAN ANGEL NAVARRO’ s love, companionship, comfort, assistance, protection, affection, society, moral support, and training and guidance. Plaintiff, MIKE ANGEL NAVARRO’ s damages exceed the minimum jurisdiction of this Court.
51. Plaintiffs’ injuries, harm, and resulting general and special damages were a direct and proximate result of the negligent, careless, wanton and unlawful acts and omissions of defendants, and each of them, as described herein.
SECOND CAUSE OF ACTION
Negligence—Survival Action Against all Defendants)
52. Plaintiffs repeat and reallege the allegations contained in Paragraphs 1 through 51, hereinabove, and incorporate the same as though fully set forth herein.
53. As a legal, direct, and proximate result of the aforementioned conduct of the Defendants, and each of them, Decedent, CRISTIAN ANGEL NAVARRO, was required to and did employ physicians and surgeons for medical examinations, treatment, and care of injuries and did incur medical and incidental expenses in an amount to be ascertained.
54. As a result of the foregoing, Plaintiffs, as the heirs of Decedent, CRISTIAN ANGEL NAVARRO, and as his successors in interest, hereby assert survivors’ claims on behalf of him, the deceased, pursuant to California Code of Civil Procedure§§ 377. 10, 377.20, 377. 30, et seq., and based upon all other applicable statutes and case law and succeed to causes of action that might have been brought by CRISTIAN ANGEL NAVARRO, deceased. Plaintiffs will file declarations under penalty of perjury as required by Code of Civil Procedure § 377.32 concurrently with this Complaint.
55. As such, Plaintiffs are entitled to compensation for Decedent, CRISTIAN ANGEL NAVARRO’S medical expenses, loss of earning capacity, and punitive damages.
PRAYER FOR WRONGFUL DEATH AND SURVIVAL DAMAGES
WHEREFORE, Plaintiffs, individually and as successors in interest and heirs, hereby pray for judgment against Defendants, and each of them, as follows:
1. Medical expenses incurred by Decedent, CRISTIAN ANGEL NAVARRO, prior to his
death;
2. Loss of earning capacity;
3. Full value of life of the decedent for his wrongful death;
4. Loss of care, comfort, society, solace, moral support, guidance and services of Decedent,
CRISTIAN ANGEL NAVARRO, to his survivors, beneficiaries, and heirs;
5. Loss of support and services in money or in kind;
6. Loss of inheritance;
7. Funeral and burial expenses;
8. For prejudgment interest, according to proof;
9. For cost of suit incurred herein, according to proof;
10. For damages for Plaintiffs other losses, according to proof; and
11. For such other and further relief as the Court may deem just and proper.
DATED: November 17, 2020 ADAMSON AHDOOT LLP
By:
PETER M. WILLIAMSON, Esq.
Attorneys for Plaintiffs
MIKE ANGEL NAVARRO and
CYNTHIA SALCIDO
DEMAND FOR TRIAL BY JURY
Plaintiffs, MIKE ANGEL NAVARRO and CYNTHIA SALCIDO, individually, and as
successors in interest to CRISTIAN ANGEL NAVARRO, deceased, hereby demand a trial by jury as
to all causes of action.
DATED: November 17, 2020 ADAMSON AHDOOT LLP
By:
PETER M. WILLIAMSON, Esq.
Attorneys for Plaintiffs
MIKE ANGEL NAVARRO and
CYNTHIA SALCIDO
Christopher B. Adamson, Esq. ( State Bar No. 238500)
Alan A. Ahdoot, Esq. (State Bar No. 238594)
Peter M. Williamson, Esq. State Bar No. 97309)
ADAMSON AHDOOT LLP
1150 South Robertson Blvd.,
Los Angeles, California 90035
Telephone: ( 310) 888- 0024
Facsimile: ( 888) 895- 4665
Attorneys for Plaintiffs
MIKE ANGEL NAVARRO & CYNTHIA SALCIDO
SUPERIOR COURT OF THE STATE OF CALIFORNIA
FOR THE COUNTY OF RIVERSIDE — HISTORIC COURTHOUSE
UNLIMITED JURISDICTION
MIKE ANGEL NAVARRO and CYNTHIA SALCIDO, individually, and as successors in interest to CRISTIAN ANGEL NAVARRO,) deceased;
PLAINTIFF CYNTHIA SALCIDO’ S
AFFIDAVIT PURSUANT TO CALIFORNIA
Plaintiff, CODE OF CIVIL PROCEDURE § 377. 32
v.
JURUPA UNIFIED SCHOOL DISTRICT,
a Public Entity; CHRISTOPHER filed Concurrently with the Complaint]
FOWLER, an individual, and DOES 1
through 100, inclusive,
Defendants.
AFFIDAVIT PURSUANT TO CALIFORNIA CODE OF CIVIL PROCEDURE § 377. 32
Filed Concurrently with the Complaint)
I, CYNTHIA SALCIDO, hereby declare as follows:
1. The decedent in the subject litigation is my son, CRISTIAN ANGEL NAVARRO,
who died on October 1, 2020, in the City of Los Angeles, County of Los Angeles, California.
2. There is no proceeding now pending in California for the administration of the decedent’s s estate.
3. I am the Decedent’s successor in interest( as defined in Code of civil Procedure§ 377. 1)
AFFIDAVIT PURSUANT TO CALIFORNIA CODE OF CIVIL PROCEDURE§ 377. 32
and succeed to the Decedent’s interest in the action or proceeding.
4. There is no other person that has a superior right to commence the action or proceeding
or to be substituted for the Decedent in the pending action or proceeding.
5. Decedent, CRISTIAN ANGEL NAVARRO’ s Certificate of Death is attached hereto
as Exhibit” A”.
I declare under penalty of perjury pursuant to the laws of the State of California that the foregoing
is true and correct.
DATED: November 18, 2020
CYNTHIA SALCIDO
AFFIDAVIT PURSUANT TO CALIFORNIA CODE OF CIVIL PROCEDURE

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