Cogburn v. Arkansas Department of Corrections

CourtDistrict Court, E.D. Arkansas
DecidedDecember 1, 2023
Docket4:23-cv-00664
StatusUnknown

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

Bluebook
Cogburn v. Arkansas Department of Corrections, (E.D. Ark. 2023).

Opinion

IN THE UNITED STATES DISTRICT COURT EASTERN DISTRICT OF ARKANSAS CENTRAL DIVISION

KEVIN COGBURN * ADC #181168, * * Plaintiff, * v. * No. 4:23-cv-00664-JJV * ARKANSAS DEPARTMENT OF * CORRECTIONS, et. al, * * Defendants. *

MEMORANDUM AND ORDER

I. INTRODUCTION Kevin Cogburn (“Plaintiff”) is a prisoner in the Arkansas Division of Correction (“ADC”). He has filed a pro se Amended Complaint, pursuant to 42 U.S.C. § 1983, alleging that from May 2 to 9, 2023, Defendants Captain Linda Arnold and Lieutenant Jarius Sanders violated his Eighth Amendment rights by confining him in an isolation cell without a toilet, drinking water, bedding, clothing, or the opportunity to shower. (Doc. 5.) All other claims and Defendants have been previously dismissed without prejudice. (Doc. 15.) And the parties have consented to proceed before me. (Doc. 16.) Defendants have filed a Motion for Summary Judgment arguing the claim against them should be dismissed without prejudice because Plaintiff failed to properly exhaust his available administrative remedies. (Docs. 17-19.) Plaintiff has not filed a Response, and the time to do so has expired. Thus, the facts in Defendants’ Statement of Facts (Doc. 19) are deemed admitted. See Local Rule 56.1(c); Jackson v. Ark. Dept. of Educ., Vocational & Tech. Educ. Div., 272 F.3d 1020, 1027 (8th Cir. 2001). And, as will be discussed herein, those facts are supported by the record. After careful consideration and for the following reasons, the Motion for Summary 1 Judgment is GRANTED, and Plaintiff’s conditions of confinement claim against Defendants Arnold and Sanders is DISMISSED without prejudice. II. SUMMARY JUDGEMENT STANDARD Summary judgment is appropriate when the record, viewed in a light most favorable to the nonmoving party, demonstrates there is no genuine dispute as to any material fact and the moving

party is entitled to judgment as a matter of law. See Fed. R. Civ. P. 56(a); Celotex Corp. v. Catrett, 477 U.S. 317, 322-23 (1986). The moving party bears the initial burden of demonstrating the absence of a genuine dispute of material fact. Celotex, 477 U.S. at 323. Thereafter, the nonmoving party cannot rest on mere denials or allegations in the pleadings, but instead, must come forward with evidence supporting each element of their claim and demonstrating there is a genuine dispute of material fact for trial. See Fed R. Civ. P. 56(c); Celotex, 477 U.S at 322; Holden v. Hirner, 663 F.3d 336, 340 (8th Cir. 2011). In this regard, a material fact dispute is “genuine” if “the evidence is sufficient to allow a reasonable jury to return a verdict for the non- moving party.” Greater St. Louis Constr. Laborers Welfare Fund v. B.F.W. Contracting, LLC,

76 F.4th 753, 757 (8th Cir. 2023). III. DISCUSSION A. The Exhaustion Requirement The Prison Litigation Reform Act (“PLRA”) provides that: “No action shall be brought with respect to prison conditions under section 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). The purposes of the exhaustion requirement include “allowing a prison to address complaints about the program it administers before being subjected to suit, reducing litigation to the extent complaints are satisfactorily

2 resolved, and improving litigation that does occur by leading to the preparation of a useful record.” Jones v. Bock, 549 U.S. 199, 219 (2007); see also Woodford v. Ngo, 548 U.S. 81, 89–91 (2006). The PLRA requires inmates to properly exhaust their administrative remedies as to each claim in the complaint and complete the exhaustion process prior to filing an action in federal court. Johnson v. Jones, 340 F.3d 624, 627 (8th Cir. 2003); Graves v. Norris, 218 F.3d 884, 885

(8th Cir. 2000). Importantly, the Supreme Court has emphasized “it is the prison’s requirements, and not the PLRA, that define the boundaries of proper exhaustion.” Jones, 549 U.S. at 218. Thus, to satisfy the PLRA, a prisoner must fully and properly comply with the specific procedural requirements of the incarcerating facility. Id. B. ADC’s Grievance Policy The ADC policy in effect at the time of the alleged constitutional violation was Administrative Directive 19-34, which establishes a three-step procedure. (Docs. 17-1, 17-2.) First, the inmate must attempt informal resolution by submitting a Unit Level Grievance Form to a designated problem solver within fifteen days of the incident. The form must include “a brief

statement that is specific as to the substance of the issue or complaint to include the date, place, personnel involved or witnesses, and how the policy or incident affected the inmate submitting the form.” (Doc. 17-2 at § IV(E)(2).) Inmates are cautioned a “[g]rievance must specifically name each individual involved in order that a proper investigation and response may be completed” and an inmate who “fails to name all parties during the grievance process may have his or her lawsuit or claim dismissed by the court or commission for failure to exhaust against all parties.” (Id. § IV(C)(4).) And the grievance form itself reminds prisoners to include the “name of personnel involved.” (Id. at 20.) The problem solver must respond to the informal resolution within three working days. (Id. § IV(E)(4) and (7).)

3 Second, if informal resolution is unsuccessful or the problem solver does not timely respond, the inmate must file a formal grievance within three working days by completing a section on the informal resolution form. (Id. § IV(E)(11) and (F)(1).) At this point, the form receives a grievance tracking number. (Id. at § IV(F)(3).) Medical grievances are sent to the Health Services Administrator (“HSA”), while all other grievances are sent to the Warden. The HSA or

Warden must provide a written response within twenty working days. (Id. § IV(F)(5) and (7).) Third, an inmate who is dissatisfied with the grievance response, or who does not timely receive a response, must appeal within five working days to the appropriate ADC Deputy Director. The policy requires a written response within thirty work days unless there is an extension. (Id. § IV(F)(9) and (G)(6).) And the response ends the grievance process. (Id.) Finally, the Directive includes the following warning: Inmates are hereby advised that they must exhaust their administrative remedies as to all defendants at all levels of the grievance procedure before filing a Section 1983 lawsuit or Claims Commission claim. If this is not done, the lawsuit or claim may be summarily dismissed.

(Id. at § IV(N).) C.

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Bluebook (online)
Cogburn v. Arkansas Department of Corrections, Counsel Stack Legal Research, https://law.counselstack.com/opinion/cogburn-v-arkansas-department-of-corrections-ared-2023.