Corniel v. NAPH Care, 3:18-cv-00157

Plaintiff Anthony Corniel, a pretrial detainee at Washoe County Detention Facility, sued under 42 U.S.C. § 1983 alleging denial of adequate medical care for a right-hand injury sustained on October 6, 2017.
Corniel alleges he was kept in solitary for ~20 days before receiving care, repeatedly requested x-rays/treatment, and that staff falsely reported he refused treatment; he claims an outside specialist on March 21, 2018 said his hand required re-breaking and pins and that he suffered two heart attacks from pain/stress.
Medical records show initial infirmary care on October 6–8, 2017 (wound care, splinting, naproxen), x-ray read October 19, 2017 confirming an index metacarpal neck fracture, and a carpal cast placed October 24, 2017.
Plaintiff was referred to orthopedics (Dr. Kirk Kaiser) and seen November 14, 2017, where Dr. Kaiser recommended non-operative treatment (splint, ROM exercises, OT) and follow-up; jail medical staff continued conservative care and pain management.
Defendants produced an orthopedic expert (Dr. Van den Bogaerde) who reviewed records and opined the care was within the standard of care; plaintiff did not file any opposition to the summary-judgment motion.
The magistrate judge recommended granting defendants’ motion for summary judgment, finding the treatment objectively reasonable and no substantial risk created by defendants.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether jail medical staff violated the Fourteenth Amendment by denying adequate medical care (deliberate indifference/objective standard)	Corniel says staff delayed and denied timely care for a broken hand, lied about refusals, needed surgical re-breaking and pins, and suffered heart attacks from pain/stress	Medical staff provided timely evaluation, imaging, immobilization, pain meds, and specialty referral; expert says care met standard; records show some refusals by plaintiff	Summary judgment for defendants — care was objectively reasonable and did not create substantial risk; claim fails
Whether summary judgment was appropriate given the record and plaintiff’s non-response	(No substantive response filed)	Defendants met their burden showing no genuine dispute of material fact; plaintiff did not produce evidence to the contrary	Summary judgment appropriate and recommended granted

Celotex Corp. v. Catrett, 477 U.S. 317 (summary judgment standard and burden shifting)
Anderson v. Liberty Lobby, Inc., 477 U.S. 242 (genuine dispute and materiality standard for summary judgment)
Gordon v. County of Orange, 888 F.3d 1118 (9th Cir. 2018) (Fourteenth Amendment medical-care claims by pretrial detainees evaluated under an objective deliberate-indifference test)
McGuckin v. Smith, 974 F.2d 1050 (9th Cir. 1992) (Eighth Amendment deliberate indifference framework for prison medical claims)
Matsushita Elec. Indus. Co. v. Zenith Radio Corp., 475 U.S. 574 (nonmoving party must show specific facts to create genuine dispute)
Gibson v. County of Washoe, 290 F.3d 1175 (9th Cir. 2002) (applying deliberate indifference standard to detainee medical claims)