Kelly Rhodes was incarcerated at Women’s Huron Valley Correctional Facility when she began working as a laundry porter. On October 15, 2015, her second day on that assignment, she was helping unload industrial laundry carts from a truck.
The carts could weigh as much as 400 pounds when loaded. They were moved from the truck on a hydraulic lift gate that did not have a stopper to keep a cart from tipping. Testimony in the case also showed there was no formal unloading procedure or formal training for new laundry porters, even though carts had tipped during earlier unloading work.
One of the loaded carts fell from the truck and struck Rhodes, knocking her onto the concrete. She suffered skull and facial fractures, brain injuries, internal bleeding, and injuries to her face, scalp, and left side.
The witnesses did not agree on every detail of how the cart fell. But evidence discussed in the appellate decision included testimony that the truck driver was rushing, released the cart without following his usual safety check, and pushed it toward Rhodes too quickly. Other testimony created a factual dispute about whether the officer operating the lift lowered it before Rhodes had control of the cart.
Rhodes brought federal civil rights claims alleging that the officials had been deliberately indifferent to the dangerous prison work conditions. The district court granted summary judgment to the two remaining officials, ending both her Eighth Amendment and substantive-due-process claims before trial.
Amy DeRouin argued Rhodes’s appeal and was on the appellant’s brief before the United States Court of Appeals for the Sixth Circuit.
In its published 2021 decision, the Sixth Circuit held that the evidence, viewed in Rhodes’s favor at the summary-judgment stage, could allow a reasonable jury to find that both officials were deliberately indifferent to a substantial risk of serious harm. The court also held that the Eighth Amendment’s protection against deliberate indifference to dangerous prison work conditions was clearly established.
The decision was a partial reversal because it reinstated the Eighth Amendment claims but left the dismissal of the substantive-due-process claims in place. It did not decide that the officials were ultimately liable. It returned the Eighth Amendment claims to the district court so Rhodes could continue pursuing them.
On May 11, 2023, the parties reached a resolution during a federal court settlement conference, and the case was dismissed with prejudice. Michigan’s public report of settlements paid by the State lists a $300,000 payment in Rhodes’s laundry-cart injury case.
The appeal gave Rhodes the opportunity to pursue her Eighth Amendment claims. After the case returned to federal district court, it ended in a $300,000 settlement.
Past results are not a guarantee. Each case depends on its facts and law.