Vanessa Chavero-Linares v. Timothy Smith, 782 F.3d 1038

Vanessa Chavero-Linares, an ICE detainee housed at Hardin County Correctional Center, alleges another inmate made threats and later struck her with a plastic chair, causing a small facial injury and short-term pain.
She reported the threatening statements to Sgt. Dennis Beadle and called ICE Agent Kevin Donnelly; she alleges Beadle ignored her and Donnelly said he could not help.
Contemporaneous evidence (photo and officer observations) showed a minor red mark, no swelling or bleeding; she took one pain pill and did not seek medical treatment.
Chavero-Linares sued county and federal officials asserting: failure-to-protect, failure-to-train, substantive-due-process, and failure-to-have-a-custody-policy claims.
The district court dismissed federal defendants (Rule 12(b)(6)) and granted summary judgment to county defendants; it also awarded qualified immunity to several officers. The Eighth Circuit affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Waiver of claims not briefed on appeal	Chavero-Linares contends various claims against McDaniel, Moore, Napolitano, and Smith	Defendants argue issues not meaningfully briefed are waived	Court: Claims against those defendants waived for failure to meaningfully brief them
Rule 12(b)(6) dismissal of failure-to-protect claim vs. Donnelly	Complaint alleges she called Donnelly about threats; implies he knew of risk	Donnelly argues allegations do not show he was aware of facts creating a substantial risk or asked to move the inmate	Court: Dismissal affirmed — allegations do not plausibly show Donnelly knew of substantial risk
Summary judgment on failure-to-protect claim vs. Beadle	Chavero-Linares argues Beadle ignored reports and failed to protect her	Beadle points to contemporaneous photo, minor injury evidence, and lack of medical complaint	Court: Summary judgment for Beadle — injury not objectively serious and plaintiff lacks probative evidence
Qualified immunity for officers (Beadle, Donnelly, Moore, Smith)	Plaintiff argues constitutional rights violated by defendants' conduct	Defendants argue conduct did not violate clearly established rights a reasonable officer would know	Court: Qualified immunity affirmed — no established constitutional violation shown

Ashcroft v. Iqbal, 556 U.S. 662 (standard for pleading plausibility)
Farmer v. Brennan, 511 U.S. 825 (deliberate indifference standard for prisoner safety)
Schoelch v. Mitchell, 625 F.3d 1041 (objective-serious-harm requirement in failure-to-protect claims)
Tolan v. Cotton, 134 S. Ct. 1861 (summary-judgment evidence must be viewed in light most favorable to nonmovant)
Frevert v. Ford Motor Co., 614 F.3d 466 (self-serving affidavits insufficient; need probative evidence)
Young v. Selk, 508 F.3d 868 (examples of notice creating duty to act to prevent harm)
Wilkins v. Gaddy, 559 U.S. 34 (distinction between excessive force and conditions-of-confinement standards)
Ulrich v. Pope County, 715 F.3d 1054 (qualified immunity standard)
Jenkins v. Winter, 540 F.3d 742 (failure to raise issues in opening brief results in waiver)
Cox v. Mortgage Elec. Registration Sys., Inc., 685 F.3d 663 (issues not meaningfully argued are waived)