Ali v. Liebel

CourtDistrict Court, N.D. Indiana
DecidedJune 30, 2025
Docket3:23-cv-00879
StatusUnknown

This text of Ali v. Liebel (Ali v. Liebel) is published on Counsel Stack Legal Research, covering District Court, N.D. Indiana primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Ali v. Liebel, (N.D. Ind. 2025).

Opinion

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF INDIANA SOUTH BEND DIVISION

MUFTI ABDUL EL-MALIK-BEY ALI,

Plaintiff,

v. CAUSE NO. 3:23-CV-879 DRL-SJF

DAVID LIEBEL et al.,

Defendants.

OPINION AND ORDER

Mufti Abdul El-Malik-Bey Ali, a prisoner at Miami Correctional Facility, sued David Liebel, William Croto, and Heather Wolfe for violating his religious rights under the First Amendment, the Religious Land Use and Institutionalized Persons Act (RLUIPA), and Indiana’s Religious Freedom Restoration Act (RFRA). He says the defendants didn’t allow him to purchase and keep religious supplies, removed his Kosher diet program, confiscated his religious books, and retaliated against him. The defendants request summary judgment because they say Mr. Ali failed to exhaust his administrative remedies. The court grants the motion. BACKGROUND Mr. Ali is a practicing Muslim who requested religious supplies and special dietary accommodations at Miami Correctional Facility [51-1 ¶ 16]. He has submitted many grievances during his time at Miami [51-3]; and here, he alleges that prison staff denied him the proper Halal and Kosher diets and deprived him of religious materials. Everyone agrees that there is no record of Mr. Ali successfully completing the proper Offender Grievance Process for these claims against these defendants, but Mr. Ali disputes whether there were effective remedies for him to exhaust. Miami has a grievance procedure and had one throughout the alleged events [51-1 ¶ 13].

It follows the standard Indiana Department of Correction (IDOC) policy because it is the only policy the IDOC recognizes for offender grievance resolution [id. ¶ 17-18; 51-2 at 3]. The policy has three steps: “(1) [a] formal attempt to solve a problem or concern following unsuccessful attempts at informal resolutions; (2) [a] written appeal to the Warden/designee; and, (3) [a] written appeal to the Department Grievance Manager” [51-2 at 3]. Offenders can use the process to raise issues including, but not limited to, policies, treatment, food, staff member actions, and

reprisals for using the grievance process [id.]. Adequate grievances are assigned a grievance number in the system and should be investigated and responded to within 15 business days [51- 1 ¶ 24]. Prisoners dissatisfied with the response to their grievances have the ability to appeal by checking the disagree box on the response and filing State Form 45473 [51-2 at 12-13]. If a prisoner doesn’t receive a receipt of a grievance or a form indicating that the Grievance Specialist has rejected the grievance within ten business days, the prisoner “shall notify the Officer

Grievance Specialist of the fact” [id. 9]. If a prisoner does not receive a response to a grievance within 20 business days, the policy allows the prisoner to “appeal as though the grievance had been denied” [id. 12]. DISCUSSION The PLRA provides that “[n]o action shall be brought with respect to prison conditions under section 1983 of this title, or any other Federal law, by a prisoner…until such administrative

remedies as are available are exhausted.” 42 U.S.C. § 1997e(a). The purpose of the exhaustion requirement is “to give the prison an opportunity to address the problem before burdensome litigation is filed.” Chambers v. Sood, 956 F.3d 979, 983 (7th Cir. 2020) (citing Woodford v. Ngo, 548 U.S. 81, 93-95 (2006)). The law takes a “strict compliance approach” to exhaustion. Dole v.

Chandler, 438 F.3d 804, 809 (7th Cir. 2006). “To exhaust remedies, a prisoner must file complaints and appeals in the place, and at the time, the prison’s administrative rules require.” Pozo v. McCaughtry, 286 F.3d 1022, 1025 (7th Cir. 2002). “[A] prisoner who does not properly take each step within the administrative process has failed to exhaust state remedies, and thus is foreclosed by § 1997e(a) from litigating.” Id. at 1024. “[U]nless the prisoner completes the administrative process by following the rules the state has established for that process, exhaustion has not

occurred.” Id. at 1023. “Failure to exhaust is an affirmative defense that a defendant has the burden of proving.” King v. McCarty, 781 F.3d 889, 893 (7th Cir. 2015). Inmates are only required to exhaust administrative remedies that are actually available. Woodford, 548 U.S. at 102. The availability of a remedy is not a matter of what appears on paper, but rather whether the process was in actuality available for the prisoner to pursue. Kaba v. Stepp, 458 F.3d 678, 684 (7th Cir. 2006). Thus, when prison staff hinder an inmate’s ability to use the

administrative process, such as by failing to provide him with the necessary forms, administrative remedies are not considered “available.” Id. In essence, “[p]rison officials may not take unfair advantage of the exhaustion requirement . . . and a remedy becomes ‘unavailable’ if prison employees do not respond to a properly filed grievance or otherwise use affirmative misconduct to prevent a prisoner from exhausting.” Dole, 438 F.3d at 809. “An administrative remedy is ‘unavailable’ if it operates as a simple dead end—with officers unable or consistently unwilling to

provide any relief to aggrieved inmates, when the administrative scheme is so opaque that it becomes, practically speaking, incapable of use, or when prison administrators thwart inmates from taking advantage of a grievance process through machination, misrepresentation, or intimidation.” Crouch v. Brown, 27 F.4th 1315, 1320 (7th Cir. 2022) (quotations omitted).

Defendants bear the burden of showing that administrative remedies were available and the plaintiff failed to exhaust them. Thomas v. Reese, 787 F.3d 845, 847 (7th Cir. 2015). That burden remains with the defendants throughout; it never shifts to the plaintiff to show that administrative remedies were unavailable. Gooch v. Young, 24 F.4th 624, 627 (7th Cir. 2022). Mr. Ali says the grievance process at Miami is effectively a dead end. Ross v. Blake, 578 U.S. 632, 643 (2016). A grievance procedure may be a dead end if officers prove to be “unable

or consistently unwilling to provide any relief to aggrieved inmates” or if “officials have apparent authority, but decline ever to exercise it.” Id. He claims that even if he had followed the proper grievance procedure, he never would have received relief. He cites the heavy load of Miami’s lone grievance specialist, Michael Gapski. Mr. Gapski receives between 400 and 700 grievances a month [57-5 Tr. 10, 23]. He operates with someone who helps out and a boss, but he is the only specialist [id. Tr. 10]. When Mr. Gapski receives a grievance, he does an investigation by pulling

camera footage and taking statements [id. Tr. 14, 18]. He doesn’t speak to the individuals who make the grievances [id. Tr. 30]. Mr. Ali says Mr. Gapski never looked into the settlement agreement that was the basis for his grievances and never spoke to Chaplain Croto or Officer Liebel about it. Mr.

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Related

Woodford v. Ngo
548 U.S. 81 (Supreme Court, 2006)
Maddox v. Love
655 F.3d 709 (Seventh Circuit, 2011)
Dole v. Chandler
438 F.3d 804 (Seventh Circuit, 2006)
Marshall King v. Robert McCarty
781 F.3d 889 (Seventh Circuit, 2015)
Darreyll Thomas v. Michael Reese
787 F.3d 845 (Seventh Circuit, 2015)
Asher Hill v. Jerry Snyder
817 F.3d 1037 (Seventh Circuit, 2016)
Ross v. Blake
578 U.S. 632 (Supreme Court, 2016)
Jonathan Chambers v. Kul Sood
956 F.3d 979 (Seventh Circuit, 2020)
Corey Crouch v. Richard Brown
27 F.4th 1315 (Seventh Circuit, 2022)

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Ali v. Liebel, Counsel Stack Legal Research, https://law.counselstack.com/opinion/ali-v-liebel-innd-2025.