Megginson v. The City of New York, 1:23-cv-06798

Facts

Charlie Coleman, a state prisoner, initiated a civil rights action under 42 U.S.C. § 1983 and the ADA while incarcerated at Marquette Branch Prison, Michigan [lines=12-13].
On November 8, 2021, Officer Kent confronted Coleman upon his release from segregation, demanding he complete a cell evaluation sheet, leading to an altercation during which Kent used offensive language [lines=118-132].
Coleman indicated intent to file a grievance after Kent allegedly threw a crumpled envelope causing irritation to his eye; Kent subsequently threatened him [lines=148-153].
Coleman filed a grievance, which was dismissed without reviewing video evidence; he alleged violations of due process and racial discrimination by several officers including Leach, Allen, and Mohrman [lines=158-220].
Coleman cited a lapse in medical care following the incident, claiming the prison healthcare providers were aware of his untreated eye injury for eight months [lines=173-178].

Issues

Whether Coleman’s allegations against Officer Kent regarding the use of excessive force and verbal harassment constitute violations of his Eighth Amendment rights [lines=451-452].
Whether the denial of medical treatment by unknown healthcare parties amounted to deliberate indifference under the Eighth Amendment [lines=652-661].
Whether Coleman’s rights to due process were violated in the grievance handling process by Defendants Allen and Leach [lines=1005-1006].
Whether there were sufficient grounds for Coleman’s Fourteenth Amendment equal protection claims based on alleged racial discrimination [lines=905-906].

Holdings

The court ruled that Coleman’s claims against Officer Kent for excessive force and verbal harassment did not meet the threshold for an Eighth Amendment violation, as Kent's actions were considered de minimis [lines=605-618].
The court found Coleman's claims against "MBP Medical" for denial of medical care failed to establish both the serious medical need and deliberate indifference required for an Eighth Amendment claim [lines=709-759].
The court concluded that Coleman could not assert due process claims regarding grievance handling, as no constitutional right exists for effective grievance procedures [lines=1022-1059].
The court dismissed Coleman’s Fourteenth Amendment equal protection claims, determining the allegations lacked the necessary factual specificity and comparators to establish claims of discrimination [lines=900-1003].

OPINION