Michael Powell v. Heidi Washington, 17-1262

Background

Powell, a Michigan prisoner, was cited for fighting and possessing a weapon and found guilty at a disciplinary hearing; he received detention, loss of privileges, and a restitution order.
He was placed in long-term administrative segregation (two different facilities) from Aug–Jan and had multiple SCC reviews; he repeatedly complained his mental health was deteriorating and said he was suicidal.
While in segregation at Oaks, Powell alleged nightly water shutoffs (12:00 a.m.–6:30 a.m.), lack of cleaning supplies, limited paper, and a nonworking cell light for ~35 days; he also alleges retaliatory transfers after filing grievances.
Powell sued under 42 U.S.C. § 1983 asserting: (1) due-process violations from segregation and disciplinary procedures; (2) retaliation; (3) Eighth Amendment conditions-of-confinement claims; and (4) deliberate indifference to psychiatric needs.
The district court dismissed under 28 U.S.C. §§ 1915(e)(2) and 1915A(b). On appeal the Sixth Circuit affirmed most dismissals but reversed as to the inadequate-light Eighth Amendment claim and remanded.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Due process — atypical and significant hardship from administrative segregation	Segregation for ~6 months with adverse effects on mental health imposed atypical and significant hardship	6 months (with periodic SCC reviews) is not atypical; SCC had some evidence (fight/weapon) to justify confinement	Not atypical/significant; no due-process violation; SCC reviews and misconduct evidence satisfied process
Due process — disciplinary hearing notice & restitution	Powell lacked 24-hour notice; restitution and trust-account deductions were improper	Records show notice and hearing scheduling; MDOC regs authorize restitution and deductions	Powell received required notice; restitution and deductions permitted by MDOC rules
Retaliation — transfer after grievances	Transfers to another facility’s segregation were retaliatory and chilling	Transfer between segregations is not an adverse action	Dismissed: transfer was not an adverse action sufficient for a retaliation claim
Conditions of confinement — water, cleaning, paper, light	Various deprivations (overnight water cutoff, lack of cleaning supplies, limited paper, no light) violated Eighth Amendment	Most deprivations were temporary/inconsequential; not extreme or deliberately indifferent	Most claims failed (temporary inconveniences). But lack of adequate lighting for ~35 days stated an Eighth Amendment deliberate-indifference claim; reversed as to light claim
Deliberate indifference — psychiatric needs	Continued segregation despite suicidal ideation and deteriorating mental health showed indifference	Powell saw mental-health professionals, had meds, and disagreed only with treatment placement; no physical injury for §1997e(e) damages	Dismissed: no physical injury shown; medical contact and treatment undermined deliberate-indifference claim

Key Cases Cited

Hill v. Lappin, 630 F.3d 468 (6th Cir. 2010) (standards for §1915(e)(2) and §1915A screening and plausibility)
Shelly v. Johnson, 849 F.2d 228 (6th Cir. 1988) (prison disciplinary hearing officers entitled to absolute judicial immunity)
Peatross v. City of Memphis, 818 F.3d 233 (6th Cir. 2016) (supervisory liability requires personal involvement)
Bickerstaff v. Lucarelli, 830 F.3d 388 (6th Cir. 2016) (court need not accept conclusory allegations without supporting facts)
Harden-Bey v. Rutter, 524 F.3d 789 (6th Cir. 2008) (atypical and significant hardship test for segregation)
Wolff v. McDonnell, 418 U.S. 539 (1974) (due-process protections in prison disciplinary proceedings)
Rhodes v. Chapman, 452 U.S. 337 (1981) (Eighth Amendment standard for conditions of confinement)
Hoptowit v. Spellman, 753 F.2d 779 (9th Cir. 1985) (adequate lighting is part of shelter; inadequate lighting can violate Eighth Amendment)
Carney v. Craven, [citation="40 F. App'x 48"] (6th Cir.) (deficient cell lighting may state Eighth Amendment claim)