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TIMOTHY FINLEY,
Plaintiff-Appellant,
v.
ERICA HUSS, Deputy Warden, Marquette Branch
Prison; SARAH SCHROEDER, Acting Deputy Warden,
Marquette Branch Prison,
Defendants-Appellees. |
No. 23-1083 |
Appeal from the United States District Court for the Western District of Michigan at Marquette.
No. 2:18-cv-00100—Robert J. Jonker, District Judge.
Argued: March 20, 2024
Decided and Filed: May 22, 2024
Before: GILMAN, McKEAGUE, and THAPAR, Circuit Judges.
_________________________
OPINION
_________________________
McKEAGUE, Circuit Judge. 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. |
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YVONNE CRADDOCK,
Plaintiff-Appellant,
v.
FEDEX CORPORATE SERVICES, INC.,
Defendant-Appellee. |
No. 23-5466 |
Appeal from the United States District Court for the Western District of Tennessee at Memphis.
No. 2:17-cv-02780—Thomas L. Parker, District Judge.
Decided and Filed: May 22, 2024
Before: GIBBONS, McKEAGUE, and STRANCH, Circuit Judges.
_________________________
OPINION
_________________________
JANE B. STRANCH, Circuit Judge. FedEx Corporate Services terminated Yvonne
Craddock’s employment following a workplace altercation. Craddock, who is African
American, sued FedEx, alleging that she was terminated because of her race in violation of Title
VII of the Civil Rights Act of 1964. Her claims were submitted to a jury, which concluded that
FedEx’s reason for termination was pretextual, but that Craddock had failed to demonstrate that
FedEx intentionally discriminated against her because of her race. Craddock appeals, arguing
that the district court abused its discretion by forcing her to bifurcate the liability and damages
portions of her trial and by excluding testimony and evidence pertaining to events post-termination; that some of the court’s trial rulings and case management decisions were improper;
that the jury verdict form was plainly erroneous; and that cumulatively, these errors warrant
reversal of the judgment and remand for a new trial. For the following reasons, we hold that the
district court did not abuse its discretion regarding the claims raised by Craddock, and AFFIRM
the jury’s verdict.
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