Attaway v. Crawford County Jail

CourtDistrict Court, S.D. Illinois
DecidedMarch 27, 2025
Docket3:23-cv-02757
StatusUnknown

This text of Attaway v. Crawford County Jail (Attaway v. Crawford County Jail) is published on Counsel Stack Legal Research, covering District Court, S.D. Illinois primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Attaway v. Crawford County Jail, (S.D. Ill. 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF ILLINOIS

MICHEAL N.B. ATTAWAY, ) ) Plaintiff, ) ) vs. ) Case No. 3:23-CV-2757-MAB ) FRED CHINN, ) ) Defendant. )

MEMORANDUM AND ORDER

BEATTY, Magistrate Judge:

This matter is currently before the Court on Defendant Fred Chinn’s motion for summary judgment on the issue of exhaustion (Doc. 72; see also Doc. 73). For the reasons explained below, the motion is granted. BACKGROUND Plaintiff Micheal Attaway filed this pro se civil rights action pursuant to 42 U.S.C. § 1983 for alleged constitutional deprivations that occurred sometime between June 14, 2022, and December 20, 2022, when he was detained at the Crawford County Jail (Doc. 18, p. 1; see also Doc. 12 (amended complaint)). Specifically, Plaintiff alleges that at some point in the latter half of 2022, he was put in a 10ft x 10ft padded cell, where he remained for 14 days, because Jail officials erroneously believed he was suicidal (Doc. 12, p. 6). He alleges that he was kept in the cell around the clock, deprived of nearly all his personal property, and could not associate with other prisoners, use the phone, or even watch TV (Id. at pp. 6, 7). After 10 days in the padded cell, Plaintiff went on a hunger strike, which lasted four days (Id.). He missed twelve consecutive meals and three evening snacks before Jail Administrator Chin responded to his request to be removed from the padded

cell (Id.). Plaintiff was then put in a single man cell for approximately 90 days until he finally received a cellmate (Id.). Following a threshold review of the complaint pursuant to 28 U.S.C. § 1915A, Plaintiff was permitted to proceed on the following claims against Jail Administrator Fred Chinn: Count 1: Fourteenth Amendment due process claim for punishing Plaintiff with placement in isolation without notice of any rule violation or a hearing regarding the same.

Count 2: Fourteenth Amendment claim for failing to timely intervene to stop Plaintiff’s hunger strike and protect him from self-harm.

(Doc. 18). On April 19, 2024, Defendant Chinn filed a motion for summary judgment, arguing that Plaintiff failed to exhaust his administrative remedies before filing suit (Doc. 72; see also Doc. 73). Defendant contends that Plaintiff filed only one grievance relevant to Count 1, and he failed to pursue it past the first level of the grievance process (Doc. 73, p. 6). Defendant further contends that Plaintiff did not file any grievances that cover his claim in Count 2 (Id.). Plaintiff filed his response in opposition just five days later (Doc. 76). He did not directly address any of the facts or arguments asserted by Defendant (see id.). Instead, he primarily contended that he was unable to submit any grievances related to the claims in this lawsuit because there were “technical glitches” every time he tried to electronically submit a grievance using the tablets at the Jail, and he was told there were no paper grievances available (see id.).

Defendant filed a reply brief on April 29, 2024, arguing that Plaintiff’s allegation about “technical glitches” preventing him from electronically submitting grievances via the tablet was demonstrably untrue (Doc. 77; Doc. 77-1). Defendant also pointed out that, “[a]side from [Plaintiff’s] false claim about ‘technical glitches,’” Plaintiff had no direct response to the motion for summary judgment and did not dispute that a grievance response was hand-delivered to him, but he failed to appeal it (Doc. 77, p. 3).

After Defendant filed his reply brief, Plaintiff inundated the Court with filings. Plaintiff filed a motion indicating that he never received a full copy of Defendant’s motion for summary judgment, which made it “virtually impossible” for him to respond (Doc. 78)—in spite of the fact that he already filed his response brief (Doc. 76). Two days later, Plaintiff asked the Court to set a Pavey hearing because he said that was the only way to

resolve the parties’ differing stories as to whether he exhausted his administrative remedies (Doc. 79). He also reiterated that he had never received a full copy of Defendant’s brief and exhibits, which was the only reason that he did not directly address Defendant’s arguments (Id.). Four days later, he refiled the exact same motion (Doc. 80), as well as a sur-reply to the motion for summary judgment (Doc. 81), and a motion asking

the Court to strike Defendant’s reply brief and the affidavits that Defendant Chinn filed in support of the motion for summary judgment (Doc. 82). Plaintiff then filed two motions about subpoenaing security footage from the Crawford County Jail (Docs. 84, 85). And finally, Plaintiff filed a “declaration,” making additional and new arguments in opposition to the motion for summary judgment (Doc. 92). The Court recently addressed this slew of motions, (see Doc. 94), and now turns to Defendant’s motion seeking

summary judgment on the issue of exhaustion. LEGAL STANDARD

Summary judgment is proper only if the movant shows that there is no genuine issue as to any material fact and they are entitled to judgment as a matter of law. FED. R. CIV. P. 56(a). In making that determination, the court must view the evidence in the light most favorable to, and draw all reasonable inferences in favor of, the nonmoving party. Apex Digital, Inc. v. Sears, Roebuck & Co., 735 F.3d 962, 965 (7th Cir. 2013) (citation omitted). Courts generally cannot resolve factual disputes on a motion for summary judgment. E.g., Tolan v. Cotton, 572 U.S. 650, 656 (2014) (“[A] judge’s function at summary judgment is not to weigh the evidence and determine the truth of the matter but to determine whether there is a genuine issue for trial.”) (internal quotation marks and

citation omitted). However, when the motion for summary judgment pertains to a prisoner’s failure to exhaust, the Seventh Circuit has held that disputed factual questions can and should be resolved by the judge (rather than a jury) as a preliminary matter in an evidentiary hearing known as a “Pavey hearing.” Smallwood v. Williams, 59 F.4th 306, 315 (7th Cir. 2023) (citing Pavey v. Conley, 544 F.3d 739, 742 (7th Cir. 2008)). Accord Wagoner

v. Lemmon, 778 F.3d 586, 590 (7th Cir. 2015); Roberts v. Neal, 745 F.3d 232, 234 (7th Cir. 2014). When a prisoner does not raise sufficient factual allegations to demonstrate a genuine dispute of material fact, then no evidentiary hearing is necessary. Jackson v. Esser, 105 F.4th 948, 957 (7th Cir. 2024) (citing Smallwood, 59 F.4th at 318). Here, as explained in detail below, there are no material issues of fact that require a hearing to resolve. DISCUSSION

The Prison Litigation Reform Act, which applies to both pretrial detainees and convicted prisoners alike, Kingsley v. Hendrickson, 576 U.S. 389, 402 (2015), provides that a prisoner may not bring a lawsuit about prison conditions unless and until he has exhausted all available administrative remedies. 42 U.S.C. § 1997e(a); Pavey v. Conley, 663 F.3d 899, 903 (7th Cir. 2011). Exhaustion is an affirmative defense, which the defendants

bear the burden of proving. Pavey, 663 F.3d at 903 (citations omitted). In order to properly exhaust their administrative remedies, the 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.

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