Whether there is a temporal proximity between Petitioner's protected conduct and the Sixth Amendment retaliation act of placement in medical segregation

QUESTION PRESENTED Jasper Lee Vick (Petitioner) filed grievances and pro se Complaint in April of 2015, asserting ¥ violations of civil rights pursuant to 42 U.S.C. §1983, for damages seeking injunctive relief, | declaratory relief, compensatory damages and special damages which amount is unspecified due to any future diabetic complications against a number of prison officials at the Tennessee's Northeast | Correction Complex ("NECX"). | The District Court screened the complaint to determine whether any portion of it should be , | dismissed because it "is frivolous, malicious, or fail to state a claim under 42 U.S.C. §1983 upon which | relief may be granted." The District Court concluded that "Vick fail to state a claim for relief and | dismissed the complaint, Petitioner timely filed his notice of appeal in the United States Court of , Appeals for the Sixth Circuit. On REMAND, the Sixth Circuit Court of Appeals concluded that "Plaintiff's fifth cause of , action, liberally construed, plausibly pleads a §1983 claim that Dr Bernard, Nurse Combs, Nurse B. Jennings, Nurse Riegal, Nurse Linkous, and Medical Officer Pardue retaliated against Plaintiff for filing grievance about his medical care, by placing him in medical segregation." [See Sixth Circuit Case No. 16-5037]. In the fifth cause of action Petitioner alleges that the undersigned Respondents, A. Combs, L. Pardue, N. Riegal, C. Bernard, Beth Jennings-Morley, S. Carmody, and N. Linkins (collective "Respondents"), retaliated against Petitioner, a (Type II diabetic) for exercising his First Amendment right August 12, 2014. Petitioner alleges that because he utilized the grievances system, August 12, 2014 regarding the medical care he received, the Respondents in retaliation, acted in concert with one’ another and placed Petitioner in medical segregation August 18, 2014, without food, or a means to call . for or get help in the event of an emergency, and without first following "TN CVORRECTION TDOC INFIRMARY PROTOCOL-POLICY", denied Petitioner blood sugar checks, and all insulin, insisting 2 | Petitioner take the deadly drug "metformin", and confiscated all Keep On Person ("KOP") | medication(s), that was prescribed in September of 2010. These actions were taken against Petitioner while Respondents were acting under color of state law, with deliberate indifference for using the grievances system. January 15, 2020, the District Court again in err, dismissed the Complaint granting Respondents summary judgment. The Petitioner timely filed notice of appeal, on February 24, 2020, and the appeal has been docketed in the Sixth Circuit Court of appeals, as case number 20-5259, the case at bar. . I. Did the Sixth Circuit err in denying Petitioner review of the district court's judgment in favor of Respondents on Whether there is a temporal proximity between Petitioner's protected conduct and the Sixth Amendment retaliation act of placement in medical segregation. Did the Sixth Circuit err denying Petitioner appellate review as to Whether Petitioner satisfied | the Sixth Circuit third element of causation in his First Amendment retaliation claim. TI. Did the Sixth Circuit err denying Petitioner appellate review as to Whether Petitioner is entitled to default judgment against Respondents Bernard, Combs, Jennings, and Linkous where the district court abused its discretion in dismissing petitioner's motion to reconsider the order Doc. 77 overruling petitioner's motion for default judgment. : IV. Did the Sixth Circuit err in denying Petitioner appellate review as to Whether the District Court improperly dismissed Respondent Riegal, and manipulated the Federal Rules of Civil Procedure to | favor the Respondents . [The Sixth Circuit Court of Appeals decline to entertain Question presented See,