Solel Umani v. Michigan Dep't of Corrections, 432 F. App'x 453

Umani, an African-American inmate at Macomb Correctional Facility, held a paid work assignment as an assistant lead in Food Service.
He left his post around February 7–12, 2005 after allegedly obtaining permission; Green asserts he left without proper checkout, leading to a misconduct ticket.
An informal hearing on February 11, 2005 found Umani not guilty; he returned to work on February 12, 2005.
Subsequently, alleged racist remarks and pressure to terminate were described, including claims that a revised work evaluation downgraded his score after the not-guilty finding.
The Classification Director had final authority to terminate inmate employees; Form 363 evidence was contested and its bearing on termination was disputed.
The district court denied summary judgment on immunity; on appeal, the Sixth Circuit reversed with instructions to enter judgment in favor of Wolfenbarger, Scott, Ignasiak, and Green on all claims.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether defendants violated a constitutional right	Umani argues his rights were violated via race-based/Constitutional equal protection harms.	Defendants contend qualified immunity shields them as no clearly established violation shown.	Qualified immunity; no underlying constitutional violation shown
Race-based equal protection claim viability	Umani asserts intentional race-based discrimination in termination decisions.	Defendants argue no direct evidence and no prima facie case under McDonnell Douglas.	No direct evidence; no prima facie case; race-based claim fails
Class-of-one equal protection claim viability	Umani alleges irrational, differential treatment compared to similarly situated prisoners.	Defendants assert legitimate security rationale and rational basis for decisions.	No rational basis shown; claim fails; qualified immunity applies
Conspiracy claim under § 1985(3)	Umani contends a racially motivated conspiracy to terminate him.	Defendants maintain failure to prove underlying constitutional violation defeats conspiracy claim.	Conspiracy claim fails due to lack of underlying constitutional violation

Harlow v. Fitzgerald, 457 U.S. 800 (1982) (officials shielded when no clearly established rights violation)
Feathers v. Aey, 319 F.3d 843 (6th Cir. 2003) (three-part qualified immunity test)
Pearson v. Callahan, 555 U.S. 223 (2009) (district court may determine which prong to address first)
Engquist v. Oregon Dep't of Agric., 553 U.S. 591 (2008) (class-of-one theory not suitable in public employment)
Overton v. Bazzetta, 539 U.S. 126 (2003) (deference to prison administrators' professional judgment)
McDonnell Douglas Corp. v. Green, 411 U.S. 793 (1973) (framework for proving discrimination via pretext)
Johnson v. Kroger Co., 319 F.3d 858 (6th Cir. 2003) (direct evidence of discrimination may be minimal)
NLRB v. Foundry Div. of Alcon Indus., 260 F.3d 631 (6th Cir. 2001) (racial slur as potential but not universal direct evidence)
Radvansky v. City of Olmsted Falls, 395 F.3d 291 (6th Cir. 2005) (conspiracy requires showing of underlying injury)