Prisons — Administrative segregation

Where a plaintiff prisoner who was placed in a heavily restrictive cell in administrative segregation and kept there for approximately three months brought an action under 42 U.S.C. 1983, a grant of summary judgment in favor of the defendants should be affirmed as to the plaintiff’s procedural due process and statutory discrimination claims but reversed as to his Eighth Amendment claim.

“Timothy Finley is serving a Michigan prison sentence while suffering from severe psychiatric disorders. Over several weeks in 2016, Finley’s mental health hit a breaking point: he repeatedly cut himself with and swallowed multiple razorblades. At the same time, his persistent misconduct made him difficult to manage. Eventually, prison officials placed Finley in a heavily restrictive cell in administrative segregation and kept him there for approximately three months. Finley now challenges that decision. He brought this action under 42 U.S.C. 1983, alleging violations of the Eighth Amendment and his right to procedural due process. He also included disability-discrimination claims under the Americans with Disabilities Act and the Rehabilitation Act.

“Finley targets two prison decisionmakers. Erica Huss, the deputy warden, assigned Finley to administrative segregation. Then Sarah Schroeder, who temporarily served as deputy warden during Huss’s leave of absence, kept Finley in administrative segregation for months. Both officials knew about Finley’s serious mental-health problems and repeated instances of self-harm. In addition, Huss made her decision despite a warning from Finley’s mental healthcare provider that solitary confinement was likely to worsen his mental health. And Schroeder failed to carry out the mental-healthcare provider’s request that Finley be promptly transferred to a treatment program. In the process, both deputy wardens likely violated Michigan’s correctional policies about mentally ill inmates in solitary confinement.

“The district court granted summary judgment to Huss and Schroeder on all claims. We agree that summary judgment was warranted for Finley’s procedural due process and statutory discrimination claims. But summary judgment was improper for Finley’s Eighth Amendment claim because he presented evidence sufficient to find that the deputy wardens violated his clearly established rights. We thus AFFIRM in part, REVERSE in part, and REMAND for further proceedings.”

Finley v. Huss; MiLW 01-108022, 52 pages; U.S. Court of Appeals for the Sixth Circuit; McKeague, J., joined by Gilman, J., Thapar, J.; Gilman, J., concurring in part and dissenting in part; Thapar, J., concurring in part and dissenting in part; on appeal from the U.S. District Court for the Western District of Michigan at Marquette; Christine A. Monta for appellant; Joshua S. Smith for appellees.

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