When Timothy Finley was in the midst of a severe mental health spiral, Michigan prison officials responded by imposing on him the one condition they knew was likely to make it worse: months of solitary confinement in a tiny windowless cell. The MacArthur Justice Center is fighting to ensure that incarcerated people like Mr. Finley have their known psychiatric needs taken seriously, not punished with damaging social isolation.
In late 2016, Mr. Finley—then a prisoner with a long history of serious mental illness—was in the midst of a severe and life-threatening mental health crisis. Over the course of several weeks, while on suicide observation, he repeatedly expressed a desire to harm himself and repeatedly did so—among other things, lacerating himself compulsively with razorblades, and, on multiple separate occasions, actually swallowing razorblades, necessitating several emergency room trips and an eventual airlift to a hospital to have the razors that were still lodged in his throat and abdomen surgically extracted.
Two deputy wardens at the prison were aware not only of Mr. Finley’s serious mental illness and these repeat instances of horrific self-harm—they were specifically aware that placement in solitary confinement was likely to exacerbate his psychiatric decline and potentially lead him to undertake further self-injury. Despite that knowledge, and despite Mr. Finley’s obvious need and repeated requests for mental health treatment, these officials elected instead to relegate Mr. Finley to months of solitary confinement in one of the prison’s most isolating segregation cells. They did so without any meaningful consultation with his mental health providers as prison policy required, and they kept him in those conditions long after his assigned mental health clinician alerted them that his treatment needs could not be met in solitary and that he should be moved to a more appropriate care setting.
Mr. Finley, acting pro se, sued the prison officials alleging Eighth Amendment, due process, and disability discrimination claims. In 2018, the MacArthur Justice Center (MJC), along with co-counsel Kirkland & Ellis, won an appeal before the Sixth Circuit that allowed Mr. Finley’s lawsuit to proceed. After years of discovery and litigation, handled jointly by MJC and the Michigan State University College of Law Civil Rights Clinic, a federal district court granted the officials summary judgment on all claims. Mr. Finley appealed that decision, represented by MJC and the UCLA Prisoners’ Rights Clinic.
UPDATE
The Sixth Circuit ruled in Mr. Finley’s favor on his Eighth Amendment claim, denying the officials qualified immunity and allowing the claim to proceed to trial. The Court also ruled that solitary confinement imposed an atypical and significant hardship on Mr. Finley given his serious psychiatric condition, and therefore that he had a liberty interest triggering procedural due process protections.