Davis v. Prison Health Service

Ricky Davis (plaintiff) was incarcerated in a Michigan prison. Davis was gay and an insulin-dependent diabetic. After being medically cleared, Davis was assigned to work offsite in a public-works program supervised by public-works officers. Other insulin-dependent diabetic prisoners were part of the same crew, but Davis was the only openly gay prisoner. The supervising officers ridiculed and belittled Davis in a manner he did not witness them using with other prisoners. The officers also made a spectacle of Davis when returning him to the prison and actively tried to avoid being chosen to strip-search him. Routinely, whichever officer was selected to search Davis would make negative comments under his breath about the task. While working one day, Davis felt like his blood sugar was dropping low. Medical personnel had provided the officers with honey packets to give to diabetic prisoners in this situation. When Davis asked for a honey packet, the officer refused to hand it directly to him. Instead, the officer gave the packet to another prisoner to pass to Davis, which Davis interpreted as the officer avoiding contact with a gay male. After consuming the honey, Davis was able to return to work and finish his shift. The public-works supervisor (defendant) had Davis removed from the work crew, citing concern about his health, but the other insulin-dependent prisoners were allowed to continue working. Davis sued the supervisor and other prison officials (defendants) in federal district court, alleging he was removed from the work crew because he was gay and that this discrimination violated his equal-protection rights under the Fourteenth Amendment. The district court dismissed the complaint, finding that the allegations did not state a valid discrimination claim. Davis appealed.