MACHELLE PEARSON, et al., v. MICHIGAN DEPARTMENT OF CORRECTIONS, HEIDI E. WASHINGTON, et al., - Articles

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MACHELLE PEARSON, et al., v. MICHIGAN DEPARTMENT OF CORRECTIONS, HEIDI E. WASHINGTON, et al.,

Posted by: Azya Thornton on Mar 26, 2026

Court: 6th Circuit Court (Published Opinions)

Attorneys 1: ARGUED: Joshua S. Smith, OFFICE OF THE MICHIGAN ATTORNEY GENERAL, Lansing, Michigan, for Appellants.

Attorneys 2: Rebekah L. Bailey, NICHOLS KASTER, PLLP, Minneapolis, Minnesota, for Appellees.

Attorneys 3: ON BRIEF: Joshua S. Smith, OFFICE OF THE MICHIGAN ATTORNEY GENERAL, Lansing, Michigan, for Appellants.

Attorneys 4: ON BRIEF: Rebekah L. Bailey, Matthew H. Morgan, Grace I. Chanin, NICHOLS KASTER, PLLP, Minneapolis, Minnesota, Cary S. McGehee, Beth M. Rivers, Channing Robinson-Holmes, PITT MCGEHEE PALMER BONANNI & RIVERS PC, Royal Oak, Michigan, Jonathan R. Marko, MARKO LAW, PLLC, Detroit, Michigan, David S. Steingold, Samantha M. Baker, LAW OFFICES OF DAVID S. STEINGOLD, PLLC, Detroit, Michigan, for Appellees.

Judge(s): WHITE, LARSEN, and MURPHY, Circuit Judges

Court Appealed: United States District Court for the Eastern District of Michigan at Detroit

MURPHY, Circuit Judge. High-level prison officials cannot operate prisons by themselves. They must assign many duties to others. This case requires us to consider when these officials might violate the Eighth Amendment if the contractors tasked with providing medical care and preventing the spread of infectious diseases perform incompetently. For several years, women detained in a Michigan prison suffered from painful rashes. Their medical providers mistakenly ruled out a contagious condition: scabies. Much later, though, an outside dermatologist found that these providers had misdiagnosed the women and that scabies had spread through the prison. Four inmates incarcerated during this time seek damages not just from the medical providers but also from various prison officials who did not treat them. The district court held that the complaint plausibly pleaded that all defendants committed “clearly established” violations of the Eighth Amendment. It thus denied the defendants’ request for qualified immunity. The non-treating prison officials have appealed. And we agree with them that our precedent would not have clearly conveyed that their reliance on the front-line medical providers was so unreasonable as to violate the Eighth Amendment. On the other hand, the inmates adequately pleaded that these officials were the proximate cause of their injuries under Michigan law. We thus reverse the district court’s denial of qualified immunity and affirm its denial of state-law immunity.

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