David Rodriguez v. Jonathan Garcia, 692 F. App'x 771

Plaintiff David Rodriguez, a pretrial detainee, sued nurse Cheryl Summerville, deputy Jonathan Garcia, Bexar County, University Health System, and two nurse’s aides under 42 U.S.C. § 1983 for incidents occurring during hospitalization and later confinement in the jail infirmary after a high-speed chase and vehicular collision.
Rodriguez alleged excessive force by Deputy Garcia during an altercation in the hospital, forcible administration of antipsychotic medication, prolonged restraints (over 30 hours), and deliberate indifference to medical needs (ignored pain/injury for 21 days).
The district court granted summary judgment for defendants (including qualified immunity for Garcia) and dismissed related state tort and municipal liability claims; Rodriguez appealed and sought appointed counsel.
On appeal Rodriguez abandoned challenges to claims against one aide (Keisha), his state tort claims, and municipal liability claims by failing to brief them.
The undisputed record: Rodriguez’s leg was injured in the collision, he underwent surgery with internal hardware, experienced hardware/plate failure requiring further surgery, exhibited psychiatric symptoms (paranoia), resisted hospital staff during the altercation, and was treated/medicated while restrained.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Excessive force by Garcia	Garcia used unreasonable force; injuries (including hardware failure) create factual dispute	Garcia confronted a resisting, unauthorized, mentally disturbed detainee and acted to prevent weapon seizure; force was objectively reasonable	Summary judgment affirmed; no genuine dispute of material fact and Garcia entitled to qualified immunity
Forced antipsychotic medication	Medication was forced in violation of rights	Medication was medically indicated given active psychiatric disorder; lawful under precedent	Summary judgment affirmed; no constitutional violation for forced medication
Prolonged restraints (>30 hrs)	Restraints violated constitutional rights	Restraints were medically driven by psychiatric status; disagreement about medical necessity is not a constitutional violation	Summary judgment affirmed; no constitutional violation
Deliberate indifference to medical needs (21-day delay)	Defendants ignored reports of pain/injury post-altercation	Summerville had no involvement after Sept. 25; Garcia was not a health-care provider and did not provide medical care during the relevant period	Summary judgment affirmed as to Summerville and Garcia; plaintiff failed to show deliberate indifference

Yohey v. Collins, 985 F.2d 222 (5th Cir. 1993) (briefing omissions constitute abandonment of issues)
Savant v. APM Terminals, 776 F.3d 285 (5th Cir. 2014) (summary judgment standard and reviewing undisputed facts)
Kingsley v. Hendrickson, 135 S. Ct. 2466 (2015) (objective reasonableness standard for force against pretrial detainees)
Tolan v. Cotton, 134 S. Ct. 1861 (2014) (summary judgment review and qualified immunity context)
Washington v. Harper, 494 U.S. 210 (1990) (constitutionality of involuntary medication of prisoners)
Gobert v. Caldwell, 463 F.3d 339 (5th Cir. 2006) (medical negligence and disagreement with treatment do not by themselves establish constitutional violation)
Ramirez v. Knoulton, 542 F.3d 124 (5th Cir. 2008) (use-of-force principles and reasonableness analysis)
Ulmer v. Chancellor, 691 F.2d 209 (5th Cir. 1982) (standard for appointment of counsel in civil cases)
Rogers v. Bromac Title Servs., L.L.C., 755 F.3d 347 (5th Cir. 2014) (standard of review for summary judgment)
Rogers v. Boatright, 709 F.3d 403 (5th Cir. 2013) (restraints and detainee rights)