Culotta v. Sullivan County

CourtDistrict Court, E.D. Tennessee
DecidedMarch 25, 2025
Docket2:24-cv-00139
StatusUnknown

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

Bluebook
Culotta v. Sullivan County, (E.D. Tenn. 2025).

Opinion

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF TENNESSEE AT GREENEVILLE

JEREMIAH CULOTTA, ) ) Plaintiff, ) ) v. ) No.: 2:24-CV-139-DCLC-CRW ) SULLIVAN COUNTY, ) ) Defendant. )

MEMORANDUM OPINION

Defendant Sullivan County filed a motion for summary judgment1 in this pro se prisoner’s civil rights action under 42 U.S.C. § 1983, alleging Plaintiff failed to exhaust his administrative remedies prior to filing suit [Doc. 16]. Plaintiff filed several responses and documents in opposition [Docs. 18, 28, 30], Defendant replied [Docs. 22, 31], and Plaintiff filed sur-replies [Docs. 33, 34]. Upon consideration of the parties’ pleadings, the summary judgment evidence, and the applicable law, the Court finds that Defendant’s motion [Doc. 16] should be GRANTED and this action DISMISSED WITHOUT PREJUDICE. I. PLAINTIFF’S ALLEGATIONS AND PROCEDURAL BACKGROUND When Plaintiff was arrested and incarcerated at the Sullivan County Jail (the “Jail”), he told staff members that he was HIV positive [Doc. 1 p. 3–4]. But while Plaintiff was housed at the Jail, his condition was not treated or monitored through laboratory testing [Id. at 4]. Plaintiff sought to grieve the issue through the Jail’s administrative process by asking Lieutenant Cole to transfer him “to prison [] or a place to receive treatment” [Id. at 2]. Nursing staff told Plaintiff “that they can not [sic] treat [him] or give [him] [his] meds” [Id.].

1 Defendant filed a motion to dismiss that the Court converted to a motion for summary judgment [See Docs. 16, 24]. Plaintiff subsequently filed this action, and the Court permitted Plaintiff to proceed on a denial-of-medical-care claim against Sullivan County [Doc. 6]. Shortly thereafter, Plaintiff was transferred to the Bledsoe County Correctional Facility, where he remains housed [See Doc. 8]. II. SUMMARY JUDGMENT STANDARD Under Rule 56 of the Federal Rules of Civil Procedure, summary judgment is proper only

when the pleadings and evidence, viewed in a light most favorable to the nonmoving party, illustrate that no genuine issue of material fact exists and the movant is entitled to judgment as a matter of law. Fed. R. Civ. P. 56(a),(c); Celotex Corp. v. Catrett, 477 U.S. 317, 322–23 (1986). To establish an entitlement to summary judgment, the moving party must demonstrate that the nonmoving party cannot establish an essential element of his case for which he bears the ultimate burden of proof at trial. Celotex, 477 U.S. at 322. Once the motion is properly supported with competent evidence, the nonmovant must show that summary judgment is inappropriate by setting forth specific facts showing there is a genuine issue for trial. Id. at 323. That is, to successfully oppose a motion for summary judgment, “the non-moving party . . . must present

sufficient evidence from which a jury could reasonably find for him.” Jones v. Muskegon Cnty., 625 F.3d 935, 940 (6th Cir. 2010). Failure to exhaust is an affirmative defense for which a defendant bears the burden of proof. Surles v. Andison, 678 F.3d 452, 458 (6th Cir. 2012). Accordingly, when a defendant in a prisoner civil rights action moves for summary judgment on exhaustion grounds, he “must show that the record contains evidence satisfying the burden of persuasion and that the evidence is so powerful that no reasonable jury would be free to disbelieve it.” Id. at 455–56 (citations and internal quotation marks omitted). Once a defendant has demonstrated that the plaintiff did not exhaust an available administrative remedy, “the burden shifts to the prisoner to come forward with evidence showing that there is something in his particular case that made the existing and generally available administrative remedies effectively unavailable to him.” Albino v. Baca, 747 F.3d 1162, 1172 (9th Cir. 2014) (citation omitted); see also Napier v. Laurel Cnty., Ky., 636 F.3d 218, 225–26 (6th Cir. 2011) (finding once defendants put forth evidence of a valid administrative process, plaintiff must present evidence to rebut the availability of that remedy to defeat motion

for summary judgment). III. RELEVANT PROOF Plaintiff was in the Jail’s custody from April 3, 2023, until he was released into Tennessee Department of Correction custody on September 15, 2024 [See Doc. 31-1 ¶ 7]. The Jail’s “Inmate Handbook” instructs inmates on the Jail’s grievance procedure, which permits a prisoner having “a complaint about a jail policy, practice, condition, or an employee, [to] complete a Grievance Form” on the kiosk within ten (10) days of the incident giving rise to the grievance [Doc. 16-3 p. 17]. There is also an appeal process, where “[i]f [the inmate] think[s] the answer to [his] grievance is unfair,” he may appeal to the Administrative Lieutenant within five days of the answer to his

grievance [Id.]. Plaintiff received a copy of the Jail’s Inmate Handbook on April 19, 2024 [Doc. 16-4]. Plaintiff filed fifty-seven (57) grievances while housed at the Jail [Doc. 31-1 ¶ 9; Doc. 31- 2]. Between July 23 and July 25, 2024, Plaintiff filed three grievances that referenced or alluded to his HIV status [Doc. 31-1 ¶ 10; Doc. 31-2 p. 19, 20]. Those grievances state as follows:2 Nurse Stephanie wanted me to give her a week to see what can be done about me getting my labs done. I am needing to get back with her to find out if she was able to find anything out concerning (RYAN WHITE) program and me being able to receive my meds. Thanks.

I need a copy of my medical records from johnson city at east tenn infectious disease center, also sign by a notary for clemency purposes. Thanks. I know

2 The Court reproduces Plaintiff’s grievances without corrections or alterations. medical has some recent medical records proving my hiv status from ETIDC from state of franklin rd at johnson city location. THANKS.

I have sign my 12 year sentence back in april. I have a medical condition that nurse stephanie and the doctor says I can not be treated for while being housed here. I need to be placed on the next train to prison. PLEASE do whatever you can to make sure my judgments come back, so that I am on the next train. I cant be trustee with the amount of tie that i have and i have already completed my M.R.T. and Parenting classes. I need to be down the road to increase my chances of making parole my first time up. THANKS.

[Doc. 31-1 ¶ 10; Doc. 31-2 p. 19, 20]. A response was issued to each grievance [See Doc. 31-2 p. 19, 20]. None of the three grievances were appealed [Doc. 31-1 ¶ 10]. IV. LAW AND ANALYSIS The Prison Litigation Reform Act (“PLRA”) provides that “[n]o 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).

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Culotta v. Sullivan County, Counsel Stack Legal Research, https://law.counselstack.com/opinion/culotta-v-sullivan-county-tned-2025.