Rodney Carter v. Sid J. Champion, 399 F. App'x 941

Carter was struck by a passing car after attempting to rob a shop; Reach, a Clinton, MS police officer, arrived and arrested him for attempted robbery.
Carter claimed he was unconscious at arrest, needed medical care, and that Reach was deliberately indifferent to his medical needs.
The district court granted summary judgment for Reach; the action proceeded on appeal under 42 U.S.C. § 1983.
The court reviews a grant of summary judgment de novo and applies the standard that there be no genuine issue of material fact for judgment as a matter of law.
The court analyzes four-quadrant qualified-immunity framework: existence of a constitutional right, its clearly established status, and objective reasonableness of the official conduct.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Did Reach's conduct violate due process through deliberate indifference?	Carter claims Reach disregarded medical needs.	No constitutional violation shown; no evidence of deliberate indifference.	No constitutional violation; no genuine issue of material fact on deliberate indifference.
Is Reach entitled to qualified immunity on the individual-capacity claim?	Constitutional right to medical care was violated and should be protected.	Conduct was not objectively unreasonable under clearly established law.	Qualified immunity defeats the claim; Reach is entitled to judgment in his favor.

Estelle v. Gamble, 429 U.S. 97 (1976) (deliberate indifference to medical needs actionable under § 1983)
Jacobs v. West Feliciana Sheriff’s Dep’t, 228 F.3d 388 (5th Cir. 2000) (Due Process requires medical care for detainees; violation actionable under § 1983)
Turner v. Houma Mun. Fire & Police Civ. Serv. Bd., 229 F.3d 478 (5th Cir. 2000) (qualified-immunity framework for municipal employees)
Thomas v. City of Dallas, 175 F.3d 358 (5th Cir. 1999) (elements of qualified-immunity analysis, including objective reasonableness)
Fortenberry v. Geter, 849 F.2d 1550 (5th Cir. 1988) (conclusory allegations do not satisfy constitutional-violation standards)
Spears v. McCotter, 766 F.2d 179 (5th Cir. 1985) (require transcript of proof relevant to determinations on appeal)
Richardson v. Henry, 902 F.2d 414 (5th Cir. 1990) (appellate record must include transcript of proof for challenged findings)
Brinkmann v. Dallas Cnty. Deputy Sheriff Abner, 813 F.2d 744 (5th Cir. 1987) (failure to appeal district-court ruling on issues)
Yohey v. Collins, 985 F.2d 222 (5th Cir. 1993) (procedural rules about appealing district-court decisions)