King v. ZAMIARA
2012 U.S. App. LEXIS 10240
| 6th Cir. | 2012Background
- King, an MDOC inmate, was transferred from Brooks (Level II) to Chippewa (Level III) in May 2000 following his involvement in Cain litigation and grievance activity.
- King faced further administrative actions including tickets for misconduct and a later increase in security level, which the district court found to be retaliatory only insofar as it related to the protected conduct.
- The Sixth Circuit previously held that King’s protected activities could support retaliation claims and remanded for causation analysis under Mt. Healthy standards.
- On remand, the district court held that Wells, Chaffee, Singleton, and Berghuis were not liable, and the court later granted judgment in favor of Singleton and Berghuis while denying it for Wells, Chaffee, and Zamiara; the panel majority reversed relevant portions and remanded.
- The majority ultimately held Wells, Chaffee, and Zamiara liable for retaliatory actions, vacating/altering the district court’s judgments, while affirming Singleton and Berghuis.
- Beckwith wrote separately, concurring in part and dissenting in part, arguing Wells, Chaffee, and Zamiara should be treated differently on causation and pointing to King’s testimony about Deputy Warden Harry.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether protected conduct causally related the security increase | King showed protected conduct caused the adverse action. | Defendants argue no causal link shown. | Remanded; causation shown for Wells, Chaffee, Zamiara; affirmed for Singleton/Berghuis. |
| Proximate causation and who can be liable in retaliation | Any actor who sets in motion adverse action can be liable. | Only those who directly caused the action or supervisors who actively participated. | Proximate causation found; subordinate/supervisory liability discussed and applied. |
| Whether Wells, Chaffee, and Zamiara can be liable under subordinate/supervisory theories | They aided or enacted steps leading to retaliation. | Limited liability for supervisors; need direct participation or encouragement. | Liability found for Wells, Chaffee, and Zamiara; district court reversed/remanded accordingly. |
| Whether Mt. Healthy burden shifting applies to the defendants | Defendants failed to prove they would have acted similarly absent protected conduct. | Mt. Healthy defense should show same action would occur regardless of protected conduct. | District court erred; plaintiffs’ burden on causation preserved; remanded for remedy. |
Key Cases Cited
- Thaddeus-X v. Blatter, - (6th Cir. 1999) (establishes causation framework in retaliation cases (en banc))
- Mt. Healthy City Sch. Dist. Bd. of Educ. v. Doyle, 429 U.S. 274 (U.S. 1977) (burden-shifting framework for causation in retaliation)
- Siggers-El v. Barlow, 412 F.3d 693 (6th Cir. 2005) (proximate causation and foreseeability in retaliation)
- Sykes v. Anderson, 625 F.3d 294 (6th Cir. 2010) (retaliation liability for actions leading to adverse action)
- Ward v. Dyke, 58 F.3d 271 (6th Cir. 1995) (no constitutional violation for punitive action solely due to grievances if not deterred)
- Hill v. Lappin, 630 F.3d 468 (6th Cir. 2010) (no First Amendment right to file frivolous grievances; limits on retaliation theory)
- Powers v. Hamilton Cnty. Pub. Defender Comm'n, 501 F.3d 592 (6th Cir. 2007) (proximity/causation principles in retaliation)
- Paige v. Coyner, 614 F.3d 273 (6th Cir. 2010) (temporal proximity as indirect evidence of retaliation)
- Siggers v. Campbell, 652 F.3d 681 (6th Cir. 2011) (supervisor liability standards under §1983)