Davidson v. Deml

CourtVermont Superior Court
DecidedMarch 27, 2025
Docket24-cv-3452
StatusPublished

This text of Davidson v. Deml (Davidson v. Deml) is published on Counsel Stack Legal Research, covering Vermont Superior Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Davidson v. Deml, (Vt. Ct. App. 2025).

Opinion

'ermont Superior Court Filed 02/27/25 Washington Chat

VERMONT SUPERIOR COURT CIVIL DIVISION Washington Unit Case No. 24-CV-03452 65 State Street Montpelier VT 05602 802-828-2091 www.vermontjudiciary.org

Brian Davidson v Nicholas Deml et al

Opinion and Order on the State's Motion to Dismiss

In his amended complaint, Inmate Brian Davidson claims that the Department of

the Corrections (DOC) is failing to give him medications that were prescribed to him in

the community and that are medically necessary, all in violation of 28 V.S.A. § 801. The

DOC has filed a motion to dismiss for lack of subject matter jurisdiction, arguing that

Mr. Davidson has failed to exhaust his administrative remedies. Mr. Davidson

acknowledges the general obligation to exhaust the grievance process before filing suit,

and he concedes that he filed three grievances and never pursued any to completion. He

argues, however, that the DOC's responses to the latter two grievance processes

foreclosed any need to proceed with those grievances further.

The current grievance system policy proceeds as follows. If the inmate and staff

are unable to resolve the issue without "engaging in the documented informal complaint

process," an informal complaint is filed. DOC Policy #320, Procedural Application § B.1.

An informal complaint consists of the inmate's description of the issue and the inmate's

"Proposed Solution." Grievance Form 1. "If a plan of resolution is not agreed upon," the

inmate may file a formal grievance. DOC Policy #320, Procedural Application J C.

Order Page 1 of 5 24-CV-03452 Brian Davidson v Nicholas Deml et al Following an investigation, responsible staff will indicate one of the following

outcomes:

i. Denied: There is no evidence to support the basis of the grievance.

ii. Meritorious in part: There is evidence to support part of the grievance.

iii. Resolved: The issue has been acknowledged and a solution is in progress or has been enacted.

Id. ¶ C.6. “Grievants dissatisfied with a grievance decision may file an appeal with the

Commissioner within 10 business days of receiving the grievance decision.” Id. ¶ E. The

Commissioner’s decision concludes the process. Id. ¶ E.6.

Evidence of 3 grievance processes are in the record: grievances

#MVRCF000000000632 (submitted April 26, 2024), # MVRCF000000001036 (submitted

July 14, 2024), and #MVRCF000000001040 (submitted July 16, 2024).

The records related to the April 26 grievance reveal that Mr. Davidson filed a

complaint with DOC that he characterized as an emergency to the effect that he had

been denied his prescription for Vyvanse and needed it. His proposed solution was that

he should immediately be given his Vyvanse. The following day, the staff response was

to reiterate the treatment plan already in place that did not include Vyvanse. Though

that effectively was a denial, staff changed the grievance disposition to “Resolved.” The

next day, Mr. Davidson escalated by filing a formal grievance, reiterating his need for

Vyvanse. The staff response again was to reiterate his treatment plan, which did not

include Vyvanse. The disposition of his grievance again was changed to “Resolved.” Mr.

Davidson did not appeal to the Commissioner.

Order Page 2 of 5 24-CV-03452 Brian Davidson v Nicholas Deml et al The records related to the July 14 grievance reveal that Mr. Davidson complained

that he needed prescriptions that he came to prison with and had been denied. His

proposed solution was one word: “lawsuit.” He indicated that his complaint was an

emergency. The staff response was to indicate that the complaint was not an emergency

and the reference to a lawsuit was considered to be an inappropriate threat to coerce

staff. The grievance disposition was changed to “Rejected.” Mr. Davidson escalated his

complaint to a formal grievance. Without additional staff response, the grievance

disposition again was changed to “Rejected.” Mr. Davidson did not appeal to the

Commissioner.

The records related to the July 16 complaint reveal that Mr. Davidson complained

that he was being refused two medications previously prescribed to him. His proposed

resolution includes his own statement that “I need to exhaust all internal administrative

remedies before I can file a lawsuit.” He indicated that his complaint was an emergency.

The staff response was that there was no emergency, and the complaint otherwise was

referred to medical staff. On July 19 the medical staff response was: “Hi Mr. Davidson,

you were seen by the Psychiatric Prescriber on 07/04/2024. She wrote you were out for 6

weeks and did not continue your stimulants while out. You were ordered Prozac 10mg

every morning. Thank you.” The grievance disposition was changed to “Resolved.” Mr.

Davidson did not escalate by filing a formal grievance, and he did not attempt to appeal

to the Commissioner.

Mr. Davidson plainly did not exhaust the grievance process during any of these

grievances. See Pratt v. Pallito, 2017 VT 22, ¶ 15, 204 Vt. 313, 319 (“A trial court lacks

Order Page 3 of 5 24-CV-03452 Brian Davidson v Nicholas Deml et al subject matter jurisdiction to hear a case if a party fails to exhaust administrative

remedies.”). His arguments against that conclusion are not convincing.

In opposition to dismissal on that basis, he argues that he had no obligation to

exhaust the July 14 process because there was no good cause for the denial of his

grievance. He says, “By rejecting Mr. Davidson’s grievance without cause, DOC has

made any further administrative remedies unavailable to him. He should not be

expected to continue filing grievances that are going to be rejected without reason.” This

argument is pays no heed to the salutary purposes of the exhaustion requirement. “The

purpose of the exhaustion requirement is ‘to afford the parties and the courts the benefit

of the administrative agency’s experience and expertise, and to afford the agency the

opportunity to cure its own errors.’” Pratt, 2017 VT 22, ¶ 14, 204 Vt. 313, 318–19. If Mr.

Davidson thought that staff improperly denied his formal grievance, he could have

appealed to the Commissioner. He did not.

He also claims that there was no need to file a formal grievance following his July

16 informal grievance because staff marked his informal grievance: “Resolved.” In his

view, the “resolved” status meant that the relief he sought was underway, and he should

not have to appeal when he is told that he will be given the relief that was requested.

This argument might have had some traction if the record in any way supported it.

Instead, the record is clear that, even if “denied” was the more accurate grievance

disposition language, Mr. Davidson’s requests for certain medications plainly were

denied, repeatedly, and the use of the word “resolved” did not create any confusion. All of

Mr. Davidson’s requests for medications were consistently denied every time staff

responded to an informal complaint or a formal grievance. And in the April 26 process,

Order Page 4 of 5 24-CV-03452 Brian Davidson v Nicholas Deml et al his informal complaint was denied but labeled “Resolved.” He nevertheless knew to file a

formal grievance in response. Moreover, he indicated that the sole reason he was filing

the July 16 grievance was to exhaust his administrative remedies. Inexplicably, he then

did not.

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