Rodriguez v. Page, 1:15-cv-00022

Plaintiff Juan Carlos Rodriguez, a long‑term paraplegic inmate, was housed in the ADC Grimes Unit ADA barracks after transfer in December 2013 and complained the facility and shower accommodations were inadequate.
Rodriguez alleged he fell on February 1, 2014, from a portable shower chair and sustained minor injuries; he sought relief against Assistant Warden Page and Warden Weekly (official and individual capacities) and medical staff Dr. Melvin Nance and RN Brenda Bridgeman.
Surviving medical claim against Nance and Bridgeman (after exhaustion rulings) alleged a reduction in catheter allotment (from three to one per week) constituted deliberate indifference; grievance GR‑14‑00394 raised the issue.
Nance testified and submitted records showing he consulted a urologist and the Spinal Cord Commission, issued an order reducing catheter frequency to one per week (providing more often than external recommendation), and instructed Rodriguez on catheter care; Bridgeman only implemented orders.
Facts show after Rodriguez’s fall the facility installed fixed, ADA‑compliant fold‑down shower seats and a ramp; Page and Weekly presented evidence the unit met ADA standards post‑modifications.
Court held summary judgment for all defendants: Bridgeman and Nance on the catheter deliberate‑indifference claim; Page on the Eighth Amendment claim (de minimis injury) and on retaliation/discrimination and ADA claims; Weekly on conditions and ADA claims.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Eighth Amendment – inadequate medical care (catheter reduction) against Nance/Bridgeman	Reduction to one catheter/week risked infection and was deliberate indifference	Medical judgment: consulted urologist and Spinal Cord Commission; provided instructions and more frequent supply than outside recommendation; Bridgeman only followed orders	Granted summary judgment for Nance and Bridgeman — no deliberate indifference
Eighth Amendment – conditions of confinement (shower chair/fall) against Page/Weekly	Provided inappropriate shower chair created substantial risk and officials were indifferent	Defendants: either unaware (Weekly) or denied responsibility; improvements made after fall; injuries were minor	Weekly: summary judgment (no prior knowledge). Page: factual issues exist but summary judgment granted due to de minimis injury
ADA Title II injunctive relief against Page/Weekly (official capacity)	Facility failed to accommodate Rodriguez’s disability	Defendants: unit made ADA‑compliant modifications; plaintiffs named officials not ADC entity; injunctive relief moot	Granted — ADA injunctive claim moot; no individual liability for money damages
Retaliation / Equal Protection re: catheter reduction against Page	Reduction retaliatory for grievances or racially motivated	Page: no role in medical decisions; deferred to medical staff; no evidence of motive	Granted — no admissible evidence of retaliation or discrimination by Page

Estelle v. Gamble, 429 U.S. 97 (1976) (Eighth Amendment requires adequate medical care)
Celotex Corp. v. Catrett, 477 U.S. 317 (1986) (summary judgment standard—moving party need not disprove opponent’s claim)
Anderson v. Liberty Lobby, Inc., 477 U.S. 242 (1986) (genuine dispute standard for summary judgment)
Matsushita Elec. Indus. Co. v. Zenith Radio Corp., 475 U.S. 574 (1986) (court construes evidence in the light most favorable to nonmoving party)
Dulany v. Carnahan, 132 F.3d 1234 (8th Cir. 1997) (elements of Eighth Amendment medical claim)
Wilson v. Seiter, 501 U.S. 294 (1991) (conditions‑of‑confinement claim standard and deliberate indifference mens rea)
Irving v. Dormire, 519 F.3d 441 (8th Cir. 2008) (Eighth Amendment claims require more than de minimis injury)