Cynthia Cardenas v. Lee County, Texas, 569 F. App'x 252

Cesar Cardenas was jailed in Lee County; after earlier hospital care he became ill again, was observed shaking with elevated vitals, vomited during the night, was not checked for vitals when found unresponsive, and was discovered dead the next morning; autopsy: multiple drug toxicity.
Plaintiff Cynthia Cardenas sued Lee County under 42 U.S.C. § 1983 and a state survivorship claim, alleging denial of medical care, a municipal policy/custom of denying care, and failure to train jail staff about medical emergencies.
Plaintiff relied on an affidavit from another inmate, Michael Sanders, who said Sheriff Meyer turned away an ambulance when Sanders was ill, causing delayed hospital treatment and serious injury.
The district court granted summary judgment for the County, finding (1) no officer had subjective knowledge of a substantial risk to Cesar (precluding single-incident deliberate indifference), (2) the Sanders and Cesar events were isolated and did not establish a municipal policy or custom, and (3) failure-to-train liability was not established because the facts did not show a pattern or a single-incident “patently obvious” need for training.
Plaintiff also argued the County failed to produce discovery related to Sanders; the district court denied sanctions and the Fifth Circuit affirmed, finding no prejudice and no abuse of discretion.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Deliberate indifference based on single incident	County officers ignored Cesar’s serious medical need the night he died	No officer had subjective knowledge that Cesar faced a substantial risk	Held for County — plaintiff conceded lack of subjective knowledge; single-incident claim fails
Municipal policy or custom (Monell)	Sanders’ ambulance denial + Cesar’s treatment delay show a County custom of denying care	County has an official policy providing 24‑hour emergency care; incidents are isolated mistakes	Held for County — incidents were isolated and insufficient to prove a custom or policy
Policy by policymaker (Pembaur theory)	Sheriff Meyer’s alleged decision to turn away ambulance created a policy causing Cesar’s harm	Sheriff Meyer was not involved in Cesar’s case; Sanders’ conduct alone cannot prove causation for Cesar	Held for County — Sheriff’s act in Sanders’ case does not establish causation for Cesar’s death
Failure to train (City of Canton theory)	County’s training on medical emergencies was inadequate and caused constitutional deprivation	Even if training was deficient, plaintiff cannot show pattern of similar violations or a single incident so obvious to establish deliberate indifference	Held for County — no pattern and the facts do not fit the narrow single‑incident exception; failure‑to‑train claim fails

Monell v. Dept. of Social Services of N.Y., 436 U.S. 658 (municipal liability requires a policy, custom, or policymaker action)
Pembaur v. City of Cincinnati, 475 U.S. 469 (individual policymaker’s decision can be municipal policy)
City of Canton v. Harris, 489 U.S. 378 (standards for municipal liability based on failure to train)
Connick v. Thompson, 563 U.S. 51 (pattern ordinarily required for failure‑to‑train; narrow single‑incident exception)
Thompson v. Upshur Cnty., Tex., 245 F.3d 447 (pretrial detainee deliberate‑indifference framework)
Snyder v. Trepagnier, 142 F.3d 791 (high standard for imposing municipal liability)
Royal v. CCC & R Tres Arboles, L.L.C., 736 F.3d 396 (summary judgment standard and viewing evidence for nonmovant)
Cousin v. Small, 325 F.3d 627 (pattern requirement in failure‑to‑train cases)
Tolan v. Cotton, 572 U.S. 650 (courts must view evidence in light most favorable to nonmovant at summary judgment)