(PC) Hesse v. County of Sacramento, 2:21-cv-01931

Michael Hesse, a former Sacramento County jail inmate, alleged that jail medical staff were deliberately indifferent to his serious medical needs related to a right finger injury, resulting in permanent deformity and pain.
Hesse claimed defendants failed to provide or authorize a splint for his finger as ordered by his outside physician, failing to follow appropriate medical protocols.
Hesse brought claims for violation of constitutional rights under the Fourteenth Amendment, municipal liability (Monell claim), and state law medical negligence against the County of Sacramento, Lynn Billet, Phoebe Foo, and Dr. Andrew Ho.
Defendants moved for summary judgment and submitted medical records and expert testimony showing their care met the applicable standard; Hesse, after his attorney withdrew, did not file any opposition or present expert evidence.
Dr. Kendrick Lee, a board-certified hand surgeon, opined that continued splinting was not required post-surgery, the care given met the standard of care, and Hesse’s injury would not have been prevented by alternative treatment.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Fourteenth Amendment deliberate indifference	Defendants ignored Hesse’s need for a splint, causing harm	Medical care met standard; splint not required; no deliberate indifference	Granted for defendants
State law medical negligence	Failure to provide splint, contrary to duty of care, caused injury	Care complied with medical standards, expert testimony confirms standard met	Granted for defendants
Monell municipal liability	County’s policy led to unconstitutional removal of medical devices	No constitutional violation occurred; no causation from policy	Granted for defendants
Requirement for expert testimony	Layperson can understand negligence and constitutional violations	Medical standard outside lay knowledge; plaintiff must rebut with expert	Defendants’ expert testimony accepted

Celotex Corp. v. Catrett, 477 U.S. 317 (summary judgment standard; moving party responsibility)
Estelle v. Gamble, 429 U.S. 97 (deliberate indifference to medical needs under Eighth Amendment)
Monell v. Department of Social Services of City of New York, 436 U.S. 658 (municipal liability)
Anderson v. Liberty Lobby, Inc., 477 U.S. 242 (material fact in summary judgment context)
Matsushita Elec. Indus. Co. v. Zenith Radio Corp., 475 U.S. 574 (summary judgment opposing standards)
Gibson v. County of Washoe, 290 F.3d 1175 (Fourteenth Amendment standard for detainee claims)
Gordon v. County of Orange, 888 F.3d 1118 (objective deliberate indifference test for pretrial detainees)
Hutchinson v. United States, 838 F.2d 390 (expert evidence required for medical standard of care)