CROUCH v. BROWN

CourtDistrict Court, S.D. Indiana
DecidedJuly 16, 2021
Docket2:20-cv-00159
StatusUnknown

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

Bluebook
CROUCH v. BROWN, (S.D. Ind. 2021).

Opinion

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF INDIANA TERRE HAUTE DIVISION

COREY CROUCH, ) ) Plaintiff, ) ) v. ) No. 2:20-cv-00159-JPH-DLP ) RICHARD BROWN, et al. ) ) Defendants. )

ORDER GRANTING MOTION FOR SUMMARY JUDGMENT AND DIRECTING ENTRY OF FINAL JUDGMENT

Corey Crouch alleges that he was held in solitary confinement in multiple Indiana Department of Correction ("IDOC") facilities from 2016 through 2019. He further contends that during that time his placement in solitary confinement was not meaningfully reviewed, and he was forced to live in oppressive and inhumane conditions. The defendants argue that they are entitled to summary judgment because Mr. Crouch failed to exhaust administrative remedies that were available to him before he filed this lawsuit. For the reasons discussed below, the defendants' motion for summary judgment is granted, and this action is dismissed. I. Legal Standards Summary judgment shall be granted "if the movant shows that there is no genuine dispute as to any material fact and the movant is entitled to judgment as a matter of law." Fed. R. Civ. P. 56(a). A "material fact" is one that "might affect the outcome of the suit." Anderson v. Liberty Lobby, Inc., 477 U.S. 242, 248 (1986). A dispute is genuine only if a reasonable jury could find for the non-moving party. Id. If no reasonable jury could find for the non-moving party, then there is no "genuine" dispute. Scott v. Harris, 550 U.S. 372, 380 (2007). The Court views the facts in the light most favorable to the non-moving party, and all reasonable inferences are drawn in the non-movant's favor. Ault v. Speicher, 634 F.3d 942, 945 (7th Cir. 2011). In accordance with Local Rule 56-1(f), the Court assumes that facts properly supported by

the movant are admitted without controversy unless the non-movant specifically disputes them. Likewise, the Court assumes that facts asserted by the non-movant are true so long as they are supported by admissible evidence. S.D. Ind. L.R. 56-1(f)(2). On a motion for summary judgment, "[t]he applicable substantive law will dictate which facts are material." National Soffit & Escutcheons, Inc., v. Superior Sys., Inc., 98 F.3d 262, 265 (7th Cir. 1996) (citing Anderson, 477 U.S. at 248). The substantive law applicable to this motion for summary judgment is the Prison Litigation Reform Act ("PLRA"), which requires that a prisoner exhaust his available administrative remedies before bringing a suit concerning prison conditions. 42 U.S.C. § 1997e(a); see Porter v. Nussle, 534 U.S. 516, 524–25 (2002). "[T]he PLRA's exhaustion requirement applies to all inmate suits about prison life, whether they involve

general circumstances or particular episodes, and whether they allege excessive force or some other wrong." Porter, 534 U.S. at 532 (citation omitted). "Proper exhaustion demands compliance with an agency's deadlines and other critical procedural rules because no adjudicative system can function effectively without imposing some orderly structure on the course of its proceedings." Woodford v. Ngo, 548 U.S. 81, 90–91 (2006) (footnote omitted); see also Dale v. Lappin, 376 F.3d 652, 655 (7th Cir. 2004) ("In order to properly exhaust, a prisoner must submit inmate complaints and appeals 'in the place, and at the time, the prison's administrative rules require.'") (quoting Pozo v. McCaughtry, 286 F.3d 1022, 1025 (7th Cir. 2002)). "In order to exhaust administrative remedies, a prisoner must take all steps prescribed by the prison's grievance system." Ford v. Johnson, 362 F.3d 395, 397 (7th Cir. 2004). As the movants, the defendants bear the burden of establishing that the administrative remedies upon which they rely were available to Mr. Crouch. See Thomas v. Reese, 787 F.3d 845,

847 (7th Cir. 2015) ("Because exhaustion is an affirmative defense, the defendants must establish that an administrative remedy was available and that [the plaintiff] failed to pursue it."). "[T]he ordinary meaning of the word 'available' is 'capable of use for the accomplishment of a purpose,' and that which 'is accessible or may be obtained.'" Ross v. Blake, 136 S. Ct. 1850, 1858 (2016) (internal quotation omitted). "[A]n inmate is required to exhaust those, but only those, grievance procedures that are capable of use to obtain some relief for the action complained of." Id. at 1859 (internal quotation omitted). II. Conditions-of-Confinement Claims Mr. Crouch describes the conditions of his confinement extensively in his complaint. See dkt. 1 at ¶¶ 200–30. Based on these allegations, the Court identified plausible Eighth Amendment

claims at screening. Dkt. 10 at 3. The parties agree that the IDOC Offender Grievance Process ("OGP") was an administrative remedy program through which Mr. Crouch could have sought relief from these conditions. Neither party asserts that any other administrative remedy program offered Mr. Crouch relief from the conditions underlying his Eighth Amendment claims. The defendants have filed two versions of the OGP that were applicable during different portions of Mr. Crouch's time in solitary confinement. Dkts. 19-2, 19-3. Because the relevant provisions of the two versions contain no material differences, the Court cites only the more recent version, dkt. 19-3. To exhaust the remedies available through the OGP, an inmate must complete four steps. See id. at §§ X–XIII. Step 1: Initially, an inmate must attempt to resolve his concern informally by discussing it "with the staff member responsible for the situation or, if there is no such single person, with the person who is in charge of the area where the situation occurs." Id. at § X. An

inmate must document his attempt to resolve the complaint informally. Id. He may do so by completing a "Request for Interview" form. Id. Step 2: If there is no informal resolution, the inmate must submit a formal grievance on State Form 45471. Id. at § XI. Within five business days, an Offender Grievance Specialist ("OGS") must either accept and log the formal grievance or reject it for failing to meet eight basic standards. Id. at § XI(B). If the OGS does not reject the grievance, he must provide a written response to the inmate within 15 business days. Id. at § XI(C). Step 3: If an inmate is not satisfied with the OGS's response, he must submit a grievance appeal written on State Form 45473 to the OGS within five business days after receiving the OGS's response. Id. at § XII. Within one business day, the OGS must forward the grievance appeal and

all relevant documents to the Warden or his designee for review. Id. The Warden or his designee must respond within five business days of receipt. Id.

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Related

Anderson v. Liberty Lobby, Inc.
477 U.S. 242 (Supreme Court, 1986)
Booth v. Churner
532 U.S. 731 (Supreme Court, 2001)
Porter v. Nussle
534 U.S. 516 (Supreme Court, 2002)
Woodford v. Ngo
548 U.S. 81 (Supreme Court, 2006)
Scott v. Harris
550 U.S. 372 (Supreme Court, 2007)
Dana Ault v. Leslie Speicher
634 F.3d 942 (Seventh Circuit, 2011)
Bobby Ford v. Donald Johnson
362 F.3d 395 (Seventh Circuit, 2004)
Curtis L. Dale v. Harley G. Lappin
376 F.3d 652 (Seventh Circuit, 2004)
Argyropoulos v. City of Alton
539 F.3d 724 (Seventh Circuit, 2008)
Trade Finance Partners, LLC v. AAR CORP.
573 F.3d 401 (Seventh Circuit, 2009)
Darreyll Thomas v. Michael Reese
787 F.3d 845 (Seventh Circuit, 2015)
Ross v. Blake
578 U.S. 632 (Supreme Court, 2016)

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Bluebook (online)
CROUCH v. BROWN, Counsel Stack Legal Research, https://law.counselstack.com/opinion/crouch-v-brown-insd-2021.