Brown v. Rayford

District Court, S.D. Illinois·Decided September 19, 2025·No. 3:24-cv-00572·Unknown

Opinion

UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF ILLINOIS

DELVON BROWN, ) ) Plaintiff, ) ) v. ) Case No. 3:24-cv-00572-GCS ) CHARLES RAYFORD, et al., ) ) Defendants. ) )

MEMORANDUM & ORDER

SISON, Magistrate Judge:

Pending before the Court is a Motion for Summary Judgment on the Issue of Exhaustion of Administrative Remedies by Defendants Curtis Dallas (“Dallas”), Charles Rayford (“Rayford”), Brendan Garcia (“Garcia”), and Geddy McDonald (collectively, “Defendants”). (Doc. 54). Plaintiff Delvon Brown (“Brown”) filed a Response and Supplement on October 23, 2024. (Doc. 61, 62). Defendants filed a reply on November 27, 2024. (Doc. 65). A hearing was held on Defendants’ motion on April 22, 2025, wherein the Court heard testimony and arguments. (Doc. 84). The Court took the matter under advisement. Id. For the reasons delineated below, Defendants’ Motion for Summary Judgment is GRANTED. (Doc. 54). PROCEDURAL BACKGROUND Brown, an inmate of the Illinois Department of Corrections (“IDOC”), brings this civil action pursuant to 42 U.S.C. § 1983 for violations of his constitutional rights at Menard Correctional Center (“Menard”). (Doc. 1). Brown filed his Complaint on February 28, 2024. (Doc. 1). Brown alleged that, after an encounter with several correctional officers, he suffered serious injuries. Id. at 3.

The Court completed a preliminary review of Brown’s Initial Complaint pursuant to 28 U.S.C. § 1915A on April 22, 2025. (Doc. 11, p. 1, 8). The Court allowed Brown to proceed on the following counts: Count 1: Eighth Amendment excessive force or failure to intervene/protect claim against Defendants Rayford, Dallas, and Hughes.

Count 2: Eighth Amendment deliberate indifference claim against Defendant Garcia for denying Plaintiff medical attention for his broken teeth or dizziness.

(Doc. 11, p. 8). FACTUAL BACKGROUND In his response to the pending Motion, Plaintiff Brown discusses the exhaustion of administrative remedies only in relation to Grievance No. K04-1023-0657. (Doc. 61, p 7). Defendants, in their reply, did the same. (Doc. 65, p. 6-7). The Court will thus focus its analysis of exhaustion of administrative remedies on this grievance. 1. Grievance No. K04-1023-0657 (Submitted on October 6, 2023) On October 6, 2023, Brown submitted Grievance No. K04-1023-0657 related to the incident on September 28, 2023. (Doc. 85, p. 6). Brown alleged that Correctional Officer Rayford told Brown to turn around and stand up. Id. Brown recalls that Rayford was with other prison officials, who he later alleges were Dallas, Garcia, and Geddy McDonald.1

1 Initially, Brown alleged that “Hughes” was a defendant. (Doc. 1, p. 2). However, Brown later substituted McDonald for Hughes. (Doc. 39). (Doc. 85, p. 6; Doc. 39). According to Brown, the men slammed Brown against a wall for disobeying an order to turn around and stand. (Doc. 85-2, p. 6-7). The men allegedly

grabbed Brown’s hair and slammed him against a wall again. Id. at 7. During the altercation, Brown claims that he spat out a tooth. Id. Brown reported dizziness, headaches, swollen gums, and half a leftover tooth that perpetuates his gum problems. Id. Brown also alleges that the prison provided no medical care. Id. Brown claims that he was kept in a cell in the cold with no sheets, and the nurses did not treat his gums. Id. Brown marked the grievance as an emergency, so it was expedited to the Grievance

Officer for a Second Level review on October 16, 2023. Id. at 6. No further action was taken until the Grievance Officer requested an extension on December 27, 2023. Id. at 9. The Chief Administrative Officer (“CAO”) granted the extension on February 2, 2024. Eventually, after Brown had initiated this action, the Nursing Supervisor wrote a memorandum stating that Brown’s grievance had been addressed. Id. at 8. Following that

report, on August 1, 2024, another Grievance Officer recommended denial of the grievance, citing the memorandum. Id. at 4. The CAO concurred with the Grievance Officer’s recommendation. Id. LEGAL STANDARDS Summary judgment is proper when a moving party cannot establish the presence

of a genuine dispute of material fact. See FED. R. CIV. Proc. 56(a). To survive a motion for summary judgement, the non-moving party must provide admissible evidence which would allow a reasonable jury to find in his or her favor. See Maclin v. SBC Ameritech, 520 F.3d 781, 786 (7th Cir. 2008). Generally, the Court’s role is to determine whether a genuine issue of material fact exists rather than evaluate the weight of the evidence, judge witness credibility, or determine the truth of the matter when determining the outcome for a

motion for summary judgement. See National Athletic Sportswear, Inc. v. Westfield Ins. Co., 528 F.3d 508, 512 (7th Cir. 2008). However, in Pavey v. Conley, the Seventh Circuit held that, “debatable factual issues relating to the defense of failure to exhaust administrative remedies” are not required to be decided by a jury but are to be determined by the judge. 544 F.3d 739, 740- 741 (7th Cir. 2008). Therefore, it is left to the Court to determine whether an inmate has

exhausted his or her remedies when the affirmative defense of non-exhaustion is raised. If the court finds that the inmate failed to exhaust administrative remedies, then the inmate is given the opportunity to exhaust should time still permit or if the failure to exhaust was innocent. Id at 742. If the court determines that the failure to exhaust was the inmate’s fault, then the case is over. Id.

Under the Prison Litigation Reform Act (“PLRA”), which governs lawsuits filed by inmates, “no action shall be brought with respect to prison conditions under § 1983 of this title, or any other Federal Law, by a prisoner confined in any jail, prison, or other correctional facility until such administrative remedies as are available are exhausted.” 42 U.S.C. § 1997e(a). This coincides with the PLRA’s statutory purpose of “afford[ing]

correction officials [the] time and opportunity to address complaints internally before allowing the initiation of a federal case.” Woodford v. Ngo, 548 U.S. 81, 93 (2006); see also Begolli v. Home Depot U.S.A., Inc., 701 F.3d 1158, 1161 (7th Cir. 2012). It affords prison administrators an opportunity to fix the problem, reduce damages, and shed light on the factual disputes that may arise in litigation. See Pozo v. McCaughtry, 286 F.3d 1022, 1023- 24 (7th Cir. 2002).

Inmates must follow their prison’s administrative rules when attempting to exhaust their administrative remedies under the PLRA. See Pozo, 286 F.3d at 1023. Plaintiff is an inmate in the IDOC and is required to correctly follow the regulations contained in the IDOC’s Grievance Procedures to properly exhaust his claims. See 20 ILL. ADMIN. CODE § 504.800, et seq. The Seventh Circuit requires strict adherence to a prison’s grievance procedures to satisfy the requirements for exhaustion under the PLRA. See Dole v.

Chandler,

Brown v. Rayford, (S.D. Ill. 2025).

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