McMillian v. Cnty. of Onondaga, 15-1128-pr

Plaintiff Frederick McMillian, proceeding pro se, sued under 42 U.S.C. § 1983 for alleged constitutional violations while in pretrial detention at Onondaga County Justice Center (OCJC).
McMillian alleged retaliation (placement on suicide watch for protected speech), due process violations arising from the conditions of suicide-watch confinement, and interference with telephone access/collect-call costs.
The District Court granted summary judgment for defendants (county officials and agencies); McMillian appealed challenging factual disputes, denial of additional discovery, and absence of sanctions.
The Second Circuit treated McMillian’s April 2, 2016 letter as a timely notice of appeal and reviewed the grant of summary judgment de novo.
The record showed McMillian was placed on suicide watch after making suicidal statements at intake; he conceded no admissible evidence created a factual dispute about those statements.
The record also showed suicide-prevention measures were reasonably related to a legitimate nonpunitive purpose and that McMillian had telephone access and means to write letters.

Issue	Plaintiff's Argument	Defendant's Argument	Held
First Amendment retaliation for placement on suicide watch	McMillian says placement was retaliatory for protected speech	Defendants say placement was based on McMillian's suicidal statements (legitimate safety reason)	Summary judgment for defendants; suicide-watch placement would have occurred absent retaliatory motive
Due process challenge to conditions of suicide-watch confinement	Conditions imposed posed unreasonable risk to health and were punitive	Conditions were suicide-prevention measures reasonably related to legitimate, nonpunitive purpose	Summary judgment for defendants; no evidence conditions posed excessive risk or were punitive
First Amendment / access to courts — telephone use and collect-call cost	Inability to use phone and cost of calls impeded access to counsel/family	McMillian had telephone access and materials to write; no record showing legal rights were impaired	Affirmed for defendants; no evidence of interference with legal rights; family communication sufficiently accommodated
Discovery and sanctions	District Court should have allowed more discovery and sanctioned defendants	District Court did not abuse discretion; no basis for sanctions	Denied; remaining arguments (discovery and sanctions) were without merit

Bennett v. Goord, 343 F.3d 133 (2d Cir. 2003) (retaliation requires protected activity and adverse action motivated by that activity)
Scott v. Coughlin, 344 F.3d 282 (2d Cir. 2003) (defendant entitled to summary judgment if adverse action would have occurred absent retaliatory motive)
Darnell v. Pineiro, 849 F.3d 17 (2d Cir. 2017) (due process test for pretrial detainee conditions: objective risk and culpable intent/recklessness)
Davis v. Goord, 320 F.3d 346 (2d Cir. 2003) (prisoner must show interference with legal rights to establish denial of access to courts)
Baez v. JetBlue Airways Corp., 793 F.3d 269 (2d Cir. 2015) (conclusory affidavits insufficient to create genuine factual dispute)
Bell v. Wolfish, 441 U.S. 520 (U.S. 1979) (run-of-the-mill restrictions on pretrial detainees analyzed against legitimate government interests)
Wolfish v. Levi, 573 F.2d 118 (2d Cir. 1978) (discussion of pretrial detainee rights, including limited telephone access)