Brown v. Sanford - RESTRICTED FILER

CourtDistrict Court, N.D. Indiana
DecidedAugust 13, 2025
Docket3:24-cv-00547
StatusUnknown

This text of Brown v. Sanford - RESTRICTED FILER (Brown v. Sanford - RESTRICTED FILER) 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
Brown v. Sanford - RESTRICTED FILER, (N.D. Ind. 2025).

Opinion

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF INDIANA SOUTH BEND DIVISION

JAMES MICHAEL BROWN,

Plaintiff,

v. CAUSE NO. 3:24-CV-547-GSL-AZ

SGT. BROOMFIELD, et al.,

Defendants.

OPINION AND ORDER James Michael Brown, a prisoner without a lawyer, is proceeding in this case on two claims. First, he is proceeding “against Sergeant Serina Day, Officer James Drummond, and [Sergeant] Mark Broomfield in their personal capacity for money damages for failing to protect him from being attacked by his cell mate in violation of the Eighth Amendment[.]” ECF 13 at 7.1 Second, he is proceeding “against the Warden of Miami Correctional Facility in his official capacity for injunctive relief related to his ongoing need for protection from other inmates at that facility[.]” Id. The defendants filed a motion for summary judgment, arguing Brown did not exhaust his administrative remedies before filing this lawsuit. ECF 34. Brown filed a response, the defendants filed a reply, Brown filed a supplemental response, and the defendants filed a supplemental reply. ECF 46, 47, 59, 62. Brown then filed an authorized sur-reply. ECF 63. The defendants’ summary judgment motion is now fully briefed and ripe for ruling.

1 Brown alleged in his complaint that the defendants failed to protect him from being stabbed by his cell mate on March 21, 2024. Summary judgment must be granted when “there is no genuine dispute as to any material fact and the movant is entitled to judgment as a matter of law.” Federal

Rule of Civil Procedure 56(a). A genuine issue of material fact exists when “the evidence is such that a reasonable [factfinder] could [find] for the nonmoving party.” Anderson v. Liberty Lobby, Inc., 477 U.S. 242, 248 (1986). To determine whether a genuine issue of material fact exists, the court must construe all facts in the light most favorable to the non-moving party and draw all reasonable inferences in that party’s favor. Heft v. Moore, 351 F.3d 278, 282 (7th Cir. 2003). A party opposing a properly supported

summary judgment motion may not rely merely on allegations or denials in its own pleading but must “marshal and present the court with the evidence she contends will prove her case.” Goodman v. Nat’l Sec. Agency, Inc., 621 F.3d 651, 654 (7th Cir. 2010). Prisoners are prohibited from bringing an action in federal court with respect to prison conditions “until such administrative remedies as are available are exhausted.”

42 U.S.C. § 1997e(a). “[A] suit filed by a prisoner before administrative remedies have been exhausted must be dismissed; the district court lacks discretion to resolve the claim on the merits, even if the prisoner exhausts intra-prison remedies before judgment.” Perez v. Wisconsin Dep’t of Corr., 182 F.3d 532, 535 (7th Cir. 1999); see also Chambers v. Sood, 956 F.3d 979, 984-85 (7th Cir. 2020). “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). The law takes a “strict compliance approach to exhaustion.” Lockett v. Bonson, 937 F.3d 1016, 1025 (7th Cir. 2019) (citation omitted). To exhaust remedies, “a prisoner must file complaints and appeals in the place, and at the time, the prison’s administrative rules require.” Id. But inmates are only required to exhaust administrative remedies that

are “available.” Woodford v. Ngo, 548 U.S. 81, 102 (2006). 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, 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 v. Chandler, 438 F.3d 804, 809 (7th Cir. 2006). The defendants argue Brown did not exhaust his available administrative remedies before filing this lawsuit because he never submitted any grievance related to

his claim that the defendants failed to protect him from being attacked by his cellmate on March 21, 2024. ECF 35 at 5. Specifically, the defendants provide an affidavit from the prison’s Grievance Specialist, who attests to the following facts: In order to exhaust his administrative remedies, Brown needed to complete three steps before filing a lawsuit: (1) a formal grievance; (2) a Level I appeal to the warden; and (3) a Level II

appeal to the Department Grievance Manager. ECF 34-1 at 2. The grievance office never received any grievance from Brown relating to his allegation that he was stabbed or that correctional officers failed to protect him in March 2024. Id. at 7. In his response, Brown concedes he never fully exhausted any relevant grievance before filing this lawsuit. The court therefore accepts that as undisputed. Instead,

Brown argues his administrative remedies were unavailable because he submitted a relevant grievance and other documents to the grievance office but never received any receipt or response from the grievance office.2 Specifically, Brown provides evidence showing the following: On March 28, 2024, Brown submitted a grievance complaining the defendants failed to protect him from an attack that occurred on March 21, 2024 (“March 28 grievance”). ECF 46-1 at 2. Brown never received any receipt or response to

this grievance. On May 31, 2024, Brown submitted a new grievance informing the Grievance Specialist he had not received any receipt or response to his March 28 grievance. Id. at 4. On June 3, 2024, Brown submitted a “Request for Interview” form to the Grievance Specialist stating he still had not received any response to his March 28 grievance. Id. at 5. Brown attests he submitted all of these documents to the grievance

office via his caseworker, but never received any receipt or response from the grievance office. Id. at 1. Here, Brown has provided evidence the grievance office made his administrative remedies unavailable by failing to respond to his March 28 grievance and subsequent

2 Brown attests he submitted these documents to the grievance office by providing them to his caseworker because he was in restrictive housing during the relevant time period. ECF 46 at 1. The defendants do not dispute that Brown was in restrictive housing. written notices.3 See Dole, 438 F.3d at 809 (a remedy becomes ‘unavailable’ if prison employees do not respond to a properly filed grievance”). In their reply, the defendants

raise two arguments.

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Related

Anderson v. Liberty Lobby, Inc.
477 U.S. 242 (Supreme Court, 1986)
Woodford v. Ngo
548 U.S. 81 (Supreme Court, 2006)
Goodman v. National Security Agency, Inc.
621 F.3d 651 (Seventh Circuit, 2010)
Dole v. Chandler
438 F.3d 804 (Seventh Circuit, 2006)
Marshall King v. Robert McCarty
781 F.3d 889 (Seventh Circuit, 2015)
Jeremy Lockett v. Tanya Bonson
937 F.3d 1016 (Seventh Circuit, 2019)
Jonathan Chambers v. Kul Sood
956 F.3d 979 (Seventh Circuit, 2020)
Dugan v. Smerwick Sewerage Co.
142 F.3d 398 (Seventh Circuit, 1998)
Estate of Eric Jack Logan v. City of South Bend
50 F.4th 614 (Seventh Circuit, 2022)

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