Jerry Worthy v. Heidi Washington

Summary

The United States District Court for the Western District of Michigan adopts the magistrate judge’s report and recommendation in an Eighth Amendment deliberate-indifference action concerning exposure to COVID-19 in prison. The court grants Defendants Burt, Steward, and King’s motion for summary judgment and denies Plaintiff’s motion for summary judgment, concluding that Plaintiff failed to show the required subjective deliberate-indifference component. The court also denies Plaintiff’s request for oral argument.

Holdings

1. Plaintiff's objections either were insufficiently specific or failed to identify error in the magistrate judge's analysis; the report and recommendation was properly adopted in full.
2. Plaintiff failed to establish the subjective component of an Eighth Amendment deliberate-indifference claim because the record did not show that Defendants' responses to the risk of COVID-19 were deliberately indifferent.
3. Defendants were entitled to summary judgment, and Plaintiff was not entitled to summary judgment.

Questions Presented

1. Whether Plaintiff's specific objections demonstrated error in the magistrate judge's report and recommendation.
2. Whether the record presented a genuine dispute of material fact as to whether Defendants were subjectively deliberately indifferent to a substantial risk of COVID-19 infection in violation of the Eighth Amendment.
3. Whether Plaintiff was entitled to summary judgment and whether Defendants were entitled to summary judgment.

Disposition

other