Curtis Harris v. Patricia Caruso
465 F. App'x 481
| 6th Cir. | 2012Background
- Harris, a Michigan prisoner, was placed in administrative segregation after July 2002 for posing a threat following an assault on staff.
- Bi-monthly reviews occurred initially, later becoming monthly; reviews were signed by housing unit staff and a Segregation Supervisor and approved by the Security Classification Committee.
- In 2004 Harris moved to Ionia; starting April 2006, monthly reviews at Ionia and then LMF referenced attitude, social adjustment, and prior misconducts; James MacMeekin signed the reviews beginning April 2006 and thereafter.
- Harris incurred multiple major misconducts at LMF (2006–2008), including assaults on staff, disobeying orders, and property destruction; despite some favorable housing-unit marks, reviews consistently indicated low potential to honor less-restrictive confinement.
- Harris alleged health deterioration in confinement, including a brain aneurysm repaired in 2004 and other conditions; he sued MDOC Director Caruso, MacMeekin, and LMF staff under 42 U.S.C. § 1983.
- The district court granted summary judgment to all defendants, finding due process satisfied, no Eighth Amendment link to confinement, no viable First/Equal Protection claims, and no supervisory liability for Caruso; Harris appeals.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Did Harris receive due process for administrative segregation? | Harris had an atypical liberty interest and, despite reviews, lacked meaningful process. | Periodic reviews with some evidence supported continued segregation; process was adequate. | Yes, meaningful periodic reviews with some evidence showed due process; no due process violation. |
| Was the district court correct to deny discovery before ruling on the Eighth Amendment claim? | Discovery was needed to show genuine disputes of material fact. | Bare allegations without specifics are insufficient; discovery denied appropriate. | Discovery denial affirmed; no reversible error at summary judgment stage. |
| Can Harris establish supervisory liability against Caruso based on denial of grievances? | Caruso's supervisory role and denial of grievances show personal involvement. | Denial of grievances alone is insufficient for supervisory liability; no personal participation shown. | Summary judgment upheld; Caruso lacked personal involvement. |
Key Cases Cited
- Sandin v. Conner, 515 U.S. 472 (U.S. 1995) (liberty interest requires atypical and significant hardship from confinement)
- H Harden-Bey v. Rutter, 524 F.3d 789 (6th Cir. 2008) (context for evaluating duration and liberty interests in segregation)
- Massachusetts Correctional Institution v. Hill, 472 U.S. 445 (U.S. 1985) (some evidence standard for disciplinary decisions, good-time context)
- Sourbeer v. Robinson, 791 F.2d 1094 (3d Cir. 1986) (distinguishes perfunctory reviews from adequate process; not controlling here)
- Summers v. Leis, 368 F.3d 881 (6th Cir. 2004) (discovery standard in § 1983/summary-judgment context; need specificity)
- Leach v. Shelby County Sheriff, 891 F.2d 1241 (6th Cir. 1989) (supervisor liability requires personal involvement)
- Shehee v. Luttrell, 199 F.3d 295 (6th Cir. 1999) (grievance-denial alone insufficient for supervisory liability)
- Hewitt v. Helms, 459 U.S. 460 (U.S. 1983) (establishes need for periodic review in segregation context (abrogated on other grounds by Sandin))