RANDY ERICKSON v. GOGEBIC COUNTY, MICHIGAN, et al., SCOTT VOIT - Articles

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RANDY ERICKSON v. GOGEBIC COUNTY, MICHIGAN, et al., SCOTT VOIT

Posted by: Azya Thornton on Apr 7, 2025

Court: 6th Circuit Court (Published Opinions)

Attorneys 1: ARGUED: Kali M. L. Henderson, SEWARD HENDERSON, PLLC, Royal Oak, Michigan, for Appellant.

Attorneys 2: Shawn C. Cabot, CHRISTOPHER TRAINOR & ASSOCIATES, White Lake, Michigan, for Appellee.

Attorneys 3: ON BRIEF: Kali M. L. Henderson, T. Joseph Seward, David D. Burress, SEWARD HENDERSON, PLLC, Royal Oak, Michigan, for Appellant.

Attorneys 4: ON BRIEF: Jonathan A. Abent, CHRISTOPHER TRAINOR & ASSOCIATES, White Lake, Michigan, for Appellee.

Judge(s): SUTTON, Chief Judge; MURPHY and BLOOMEKATZ, Circuit Judges

Court Appealed: United States District Court for the Western District of Michigan at Marquette

MURPHY, Circuit Judge. This appeal asks whether a corrections officer violated the Eighth Amendment both by using excessive force and by failing to obtain medical care afterward. The officer threw an inmate to the ground and kneed him in the back for failing to comply with an order. The district court denied the officer’s qualified-immunity defense at the summary-judgment stage. We agree with the district court that a reasonable jury could find that the officer maliciously used force to retaliate against the inmate for his disrespectful language. And this version of the facts would show that the officer violated clearly established law. On the other hand, we disagree with the district court that a reasonable jury could find that the officer deliberately disregarded the inmate’s medical needs. No evidence suggests that the officer even knew of the inmate’s injuries. All told, then, we affirm in part and reverse in part.

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