Schrader v. Ruggles, 20-11257

Schrader arrived at Erath County Jail with a broken ankle after a fall during arrest; emergency room treated him with a splint, crutches, ice instructions, and one dose of Tramadol and prescribed Tramadol as needed.
He was booked Jan 30, 2018, housed in a holding cell for two days (given ice, cell, and doses of Tramadol twice daily), then moved to a medical cell on Feb 1 (given crutches to move but not kept) and had an intercom for requests.
Nurse Julie Ruggles dispensed medication at the jail but could not prescribe; she worked part-time and did not examine or speak with Schrader on Jan 30 and did not work Jan 31.
On Feb 1 nurse practitioner Laurie Srubar changed Schrader’s medication from Tramadol to ibuprofen; Ruggles and other nurses were not authorized to give Tramadol thereafter; Schrader requested Tramadol several times but received ibuprofen instead.
Schrader saw an orthopedics specialist on Feb 2 who scheduled surgery for Feb 9; jail sought and obtained his release on bond Feb 8 so he could recuperate at home; surgery succeeded without complications.
Schrader sued under 42 U.S.C. § 1983 alleging deliberate indifference; the district court granted summary judgment for defendants; Schrader appeals only as to Ruggles.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the deprivation was objectively sufficiently serious	Ruggler’s failure to personally assess or ensure ER instructions were followed denied basic necessities and pain control	Schrader received ice, medication, a cell, intercom, crutches/walker/wheelchair at times — no denial of minimal necessities	Court: Not sufficiently serious; care provided and substitute pain med (ibuprofen) foreclose serious-deprivation claim
Whether Ruggles acted with deliberate indifference (subjective awareness)	Ruggles knew of his injury and failed to monitor, assess, or override inadequate care	Ruggles lacked authority to prescribe/override Srubar; records show she was told Schrader refused to be seen; no evidence she was aware of a substantial risk	Court: No evidence Ruggles was subjectively aware of substantial risk or disregarded it; no deliberate indifference
Whether any delay or change in treatment caused substantial harm	Delay/withholding of Tramadol and limited nursing contact caused harm and risk of worsening injury	Schrader saw specialist Feb 2 and had timely surgery with no complications; no substantial harm shown from jail care or timing	Court: No substantial harm from any delay; medical outcome undermines claim of actionable delay

Farmer v. Brennan, 511 U.S. 825 (1994) (establishes deliberate indifference standard: objective seriousness and subjective awareness)
Wilson v. Seiter, 501 U.S. 294 (1991) (deliberate indifference requires culpable mental state)
Rhodes v. Chapman, 452 U.S. 337 (1981) (definition of denial of minimal civilized measure of life’s necessities)
Gobert v. Caldwell, 463 F.3d 339 (5th Cir. 2006) (disagreement with medical treatment, without exceptional circumstances, is not deliberate indifference)
Domino v. Texas Dep’t of Crim. Just., 239 F.3d 752 (5th Cir. 2001) (deliberate indifference is an extremely high standard)
Easter v. Powell, 467 F.3d 459 (5th Cir. 2006) (delay in care actionable only if deliberate indifference results in substantial harm)
Mendoza v. Lynaugh, 989 F.2d 191 (5th Cir. 1993) (same: delay must produce substantial harm to be actionable)
Cadena v. El Paso Cnty., 946 F.3d 717 (5th Cir. 2020) (Fourteenth Amendment standard for pretrial detainees equivalent to Eighth Amendment medical claims)
Hagen v. Aetna Ins. Co., 808 F.3d 1022 (5th Cir. 2015) (summary judgment review is de novo)