Michael Collins Iheme v. Warden Michelle Smith

Minnesota inmate Michael Collins Iheme appeals the district court’s pre-service dismissal of his civil action against prison officials at the Stillwater Correctional Facility. We reverse and remand for further proceedings.

Iheme’s complaint was prepared using a court-provided form for 42 U.S.C. § 1983 actions, but he also invoked Title VII, 42 U.S.C. § 2000e-3. He alleged the following. In September 2011, defendant Tony Forchas terminated him from his prison job in retaliation for Iheme’s complaining about racial harassment by another (white) inmate. Thereafter, Iheme was moved to a…