Duran v. Donaldson, 663 F. App'x 684

Mr. Duran, a state prisoner, sued Dr. Donaldson and Nurse Curtis under § 1983 for Eighth Amendment medical and mental-health rights violations at CCADC from Oct 2007 to May 2008.
Hand wound: after a fight, Duran was treated with antibiotics, wound reclosure by Curtis, and later by specialists; bone culture and physical therapy were recommended but not completed.
Mental health: Duran with a history of anxiety and aggression received psychotropic medications; he claimed inadequate monitoring and access to outside psychiatrists, and that Curtis impeded proper treatment.
District court granted summary judgment for Dr. Donaldson and dismissed Nurse Curtis on qualified immunity grounds.
On appeal, the Tenth Circuit reviews de novo the summary-judgment grant and the qualified-immunity dismissal, liberally construing pro se filings.
The court affirmed, concluding no Eighth Amendment violation was shown for either hand wound or mental-health care.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether hand-wound care amounted to deliberate indifference	Duran asserts significant delays/denials and failure to follow a surgeon’s plan caused harm.	Courts should not find deliberate indifference without evidence of substantial harm or causal link.	No substantial harm; no causal link shown; no objective seriousness.
Whether mental-health care showed deliberate indifference	Curtis ignored medication requests and access to outside care; Donaldson prescribed meds without personal exam.	Medical treatment was provided; no evidence of awareness of substantial risk or disregard of it.	No evidence of awareness of substantial risk; no causal link to aggression; no deliberate indifference.
Whether qualified immunity shielded Curtis from § 1983 claims	Curtis’s conduct violated clearly established rights by denying care and gating access to outside providers.	No clearly established constitutional violation; actions were reasonable in context.	Summary judgment affirmed; Curtis entitled to qualified immunity.

Estelle v. Gamble, 429 F.2d 97 (U.S. 1976) (deliberate indifference standard for medical need)
Farmer v. Brennan, 511 U.S. 825 (U.S. 1994) (objective and subjective components of Eighth Amendment standard)
Mata v. Saiz, 427 F.3d 745 (10th Cir. 2005) (medical-need seriousness and causation guidance)
Rhodes v. Chapman, 452 U.S. 337 (U.S. 1981) (minimal civilizational necessities standard for Eighth Amendment harms)
Hudson v. McMillian, 503 U.S. 1 (U.S. 1992) (extreme deprivations required for Eighth Amendment harm)
Sealock v. Colorado, 218 F.3d 1205 (10th Cir. 2000) (delay in medical care requires substantial harm for violation)
Martinez v. Beggs, 563 F.3d 1082 (10th Cir. 2009) (deliberate-indifference standard and burden on plaintiff)
Wirsching v. Colorado, 360 F.3d 1191 (10th Cir. 2004) (waiver rule for failure to object to magistrate)