Mark Morris v. Kelley Cradduck, 954 F.3d 1055

Mark Morris was detained April 2013–May 2014 and complained of testicular pain and swelling; an outside urologist (Dr. Hewett) treated him and ultimately recommended removal of an inflamed epididymal tube on August 7, 2013.
Watson (jail nurse) attempted to schedule the recommended surgery; she says she made ~15 calls to Dr. Hewett’s office, but the office delayed scheduling and later expressed concern about county payment.
The sheriff’s office provided a payment-guarantee letter (facsimiled by Watson) but Dr. Hewett thereafter canceled an October appointment and refused to continue treating Morris.
Watson then scheduled Morris with another urologist (Dr. Zimmerman), who performed the surgery October 31, 2013; Morris later required a second testicular surgery, but the treating physician opined the scheduling delay did not cause the second surgery.
Morris sued under 42 U.S.C. § 1983 alleging deliberate indifference (Fourteenth Amendment due process as a pretrial detainee) against Watson and Sheriff Cradduck (individually and officially), and alleged a county policy/custom of disregarding medical grievances; the district court granted summary judgment for defendants and the Eighth Circuit affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Watson’s delay in scheduling surgery amounted to deliberate indifference to a serious medical need	Watson delayed surgery for nonmedical, budgetary reasons, causing prolonged pain	Watson repeatedly tried to schedule surgery, arranged payment guarantee, provided meds, and the delay was caused by the physician’s office	No deliberate indifference; conduct at most negligent
Whether Cradduck is individually liable as Watson’s supervisor	Cradduck shielded himself from detainee complaints and failed to supervise Watson	Supervisor liability requires the supervisor’s own unconstitutional action; Watson did not violate rights here	No supervisory liability because no underlying constitutional violation by Watson
Whether the county is liable under Monell (official-capacity claim)	County had a custom/policy of disregarding medical grievances from problematic detainees	Municipal liability requires an underlying constitutional violation and a municipal policy/custom causing it	Official-capacity claims fail for lack of constitutional violation
Whether factual disputes (e.g., missing call/payment records) preclude summary judgment	Absence of records creates genuine disputes about Watson’s efforts	No evidence requirement to document scheduling calls or payment letters in medical chart; plaintiff produced no contrary evidence	No genuine dispute of material fact; summary judgment proper

Estelle v. Gamble, 429 U.S. 97 (deliberate indifference to serious medical need states constitutional claim)
Anderson v. Liberty Lobby, Inc., 477 U.S. 242 (summary judgment standard)
Barton v. Taber, 908 F.3d 1119 (pretrial detainee claim requires objective serious medical need and subjective deliberate indifference)
Hartsfield v. Colburn, 371 F.3d 454 (delay of prescribed care for nonmedical reasons can be deliberate indifference)
Ashcroft v. Iqbal, 556 U.S. 662 (supervisory liability requires the supervisor’s own unconstitutional conduct)
City of Los Angeles v. Heller, 475 U.S. 796 (official-capacity suit is treated as a municipal claim)
McCoy v. City of Monticello, 411 F.3d 920 (municipal liability requires a constitutional violation and causal municipal policy)