Gill v. Smith
The plaintiff filed a civil rights action against Defendant Gregory E. Smith, alleging violations of his Eighth Amendment right due to exposure to environmental tobacco smoke (ETS) and First/Eighth Amendment rights due to retaliation threats. The Magistrate Judge recommended granting summary judgment for the defendant on both claims. However, Chief Judge Scullin adopted the recommendation only in part, granting summary judgment for the defendant on the First Amendment retaliation claim, as the alleged threats did not deter the plaintiff. Crucially, the Chief Judge denied the defendant's motion for summary judgment regarding the Eighth Amendment ETS claim, finding material issues of fact concerning the level of ETS exposure and the defendant's deliberate indifference to the plaintiff's medical condition. The Chief Judge also denied the defendant's qualified immunity defense and the plaintiff's cross-motion for summary judgment, thereby allowing the Eighth Amendment claim to proceed.