## Facts

- On May 22, 1981, prisoners at the State Prison of Southern Michigan (Jackson/SPSM) rioted following an allegedly illegal prison lockdown imposed by corrections officers who were members of the Michigan Corrections Organization (MCO), a labor union.
- Prison authorities regained control on May 23, 1981, but another riot occurred on May 26, 1981.
- In response, prison guards imposed restrictive conditions, allegedly including denial of access to the yard, law library, cafeteria, hygiene/shower facilities, religious services, and rehabilitation programs.
- Beginning in June 1981, individual SPSM prisoners filed multiple federal civil-rights suits seeking declaratory relief and money damages against MCO, individual guards, and various Michigan corrections officials.
- The district court consolidated the prisoner cases for pretrial purposes under the caption *In re Jackson Lockdown/MCO Cases*.
- Separately, a federal class action (the “Walker” action) challenged conditions of confinement at three Michigan prisons, including post-riot conditions at SPSM, and sought only declaratory and injunctive relief; the Walker complaint stated class members would bring damages claims individually, and the Walker court limited certification to declaratory and prospective relief.
- After trial, the Walker court found some conditions unconstitutional. While that judgment was on appeal, MCO argued in these consolidated damages cases that Walker barred the prisoners’ damages suits because the class had not pursued damages, and that allowing separate damages actions improperly split a single cause of action.
- In this opinion, the court addressed motions to dismiss asserting, among other defenses, lack of state action as to MCO, failure to plead personal involvement by officials, Eleventh Amendment immunity, and failure to state claims under 42 U.S.C. §§ 1985(2), 1985(3), and 1986, along with challenges to pendent Michigan-law claims.

## Issues

1. Whether the complaints plausibly alleged that MCO and union-member guards acted “under color of state law,” allowing § 1983 claims to proceed against them at the pleading stage.
2. Whether the complaints adequately alleged personal involvement by state corrections officials (as opposed to liability based only on supervisory status) for claimed constitutional violations arising from lockdown and post-riot restrictions.
3. Whether the prisoners stated a claim under § 1985(3), including whether they alleged a qualifying protected class and the required class-based, invidiously discriminatory animus, and whether the intra-corporate conspiracy doctrine barred the alleged conspiracy.
4. Whether the prisoners stated a claim under § 1985(2) and, if not, whether derivative liability under § 1986 could stand.
5. Whether Eleventh Amendment immunity barred damages claims against the State of Michigan, its agencies, and state officials sued in their official capacities.
6. Whether the court should exercise supplemental (pendent) jurisdiction over Michigan-law claims and, if so, which pleaded state-law theories were legally sufficient.
7. Whether the Walker class action judgment precluded these individual damages actions under res judicata/claim-splitting principles.

## Decision

- The court declined to dismiss the § 1983 claims against MCO and its member guards on the ground that they were purely private actors, holding that the alleged use or misuse of official authority in connection with prison control and discipline was sufficient at the pleading stage to treat the conduct as under color of state law.
- The court rejected across-the-board dismissal of § 1983 claims against state officials where the pleadings alleged their involvement in, knowledge of, or responsibility for the challenged post-riot conditions; it also reiterated that § 1983 does not allow liability based only on respondeat superior.
- The court dismissed most (and effectively all) § 1985(3) conspiracy claims because the complaints did not satisfy the statute’s class-based discriminatory animus requirement as applied in Sixth Circuit authority, and because the intra-corporate conspiracy doctrine further limited conspiracy theories premised on actors within the same governmental entity acting within the scope of their roles.
- The court dismissed the § 1985(2) claims for failure to allege the required obstruction/intimidation tied to judicial proceedings and dismissed § 1986 claims because § 1986 depends on a viable § 1985 claim.
- The court held that Eleventh Amendment immunity barred damages claims against the State of Michigan and state agencies and barred damages claims against state officials sued in their official capacities, while leaving individual-capacity damages claims (and any properly pleaded prospective-relief claims against appropriate officials) available.
- The court retained certain pendent Michigan-law claims that arose from the same events and were adequately pleaded (including negligence-type theories against state actors and intentional infliction of emotional distress-type allegations against MCO), but dismissed legally insufficient theories, including contract-based claims premised on prisoners’ alleged rights under the state’s employment arrangements with the union.
- On res judicata/claim-splitting, the court rejected MCO’s argument that the Walker class action barred these damages cases, emphasizing that Walker was certified and tried only for declaratory and injunctive relief and expressly contemplated separate individual damages suits.

## Legal Principles

- A private organization and its members can be treated as acting under color of state law for § 1983 purposes when the challenged conduct is alleged to be carried out through state-conferred authority and in joint participation with state officials.
- § 1983 liability requires personal involvement in the constitutional violation; supervisory title alone is not enough.
- Restrictions imposed after a prison disturbance may raise constitutional questions that often cannot be resolved on the pleadings when the legitimacy, scope, and duration of the restrictions are fact-dependent.
- A § 1985(3) claim requires a conspiracy motivated by class-based, invidiously discriminatory animus; status as “prisoners,” without more, generally does not satisfy that requirement under controlling circuit authority.
- The intra-corporate conspiracy doctrine can defeat § 1985(3) claims where the alleged conspirators are officials or employees of the same entity acting within the scope of their employment.
- § 1986 provides a cause of action only when there is a valid underlying § 1985 violation.
- The Eleventh Amendment bars federal damages actions against a state, its agencies, and state officials in their official capacities absent waiver or valid congressional abrogation.
- A prior class action limited to declaratory and injunctive relief, and structured to reserve damages for individual actions, does not bar later individual damages suits by class members based on the same general events.

## Conclusion

*In re Jackson Lockdown/MCO Cases* addressed consolidated prisoner civil-rights suits arising from the May 1981 SPSM riots and the ensuing lockdown. The court allowed the core § 1983 claims to proceed against MCO/union guards and against appropriate state officials (subject to personal-involvement limits), dismissed the statutory conspiracy claims under §§ 1985(2), 1985(3), and 1986 for failure to meet required elements, applied Eleventh Amendment immunity to bar damages claims against the State and official-capacity defendants, managed the related Michigan-law claims by allowing some and dismissing others, and held that the earlier Walker class action for equitable relief did not preclude these separate damages actions.


In re Jackson Lockdown/MCO Cases, 568 F. Supp. 869 (1983)