Foster v. Culclager

CourtDistrict Court, E.D. Arkansas
DecidedOctober 6, 2025
Docket4:25-cv-00052
StatusUnknown

This text of Foster v. Culclager (Foster v. Culclager) 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
Foster v. Culclager, (E.D. Ark. 2025).

Opinion

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

DANNY FOSTER * ADC #169352, * * Plaintiff, * v. * No. 4:25-cv-00052-JJV * AUNDREA F. CULCLAGER, * Deputy Director, Health & Correctional * Program; et al. * * Defendant. *

MEMORANDUM AND ORDER

I. INTRODUCTION

Plaintiff, Danny Foster, says Defendants Drs. James Smith, Guy Henry, and David Fort have failed to provide him with constitutionally adequate medical care for shoulder pain and impose appropriate work restrictions. (Doc. 2.) He also alleges Defendant Deputy Aundrea F. Culclager learned about these issues while reviewing his grievances but failed to take appropriate corrective action. Plaintiff brings these claims against Defendants in their personal capacities only, and he seeks monetary damages as well as injunctive relief. Defendant Culclager has now filed a Motion for Summary Judgment arguing the claims against her should be dismissed without prejudice because Plaintiff failed to exhaust his available administrative remedies. (Doc. Nos. 28-30.) Plaintiff has responded, (Doc. Nos. 32-33), so the matter is ripe for a decision. After careful consideration and for the following reasons, I find Defendant’s Motion should be granted and this case should be dismissed without prejudice.

1 II. SUMMARY JUDGEMENT STANDARD Summary judgment is appropriate when the record, viewed in the 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 the 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 factual 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. Exhaustion Requirement The Prison Litigation Reform Act (“PLRA”) provides, in part, 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 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).

2 The PLRA requires inmates to fully and properly exhaust their administrative remedies as to each claim in the complaint. 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. The only exception is if administrative remedies are unavailable. 42 U.S.C. § 1997e(a) (prisoners are only required to exhaust “available” administrative remedies). Administrative remedies are “unavailable” if, for instance: (1) the grievance procedure “operates as a simple dead end;” (2) the procedure is “so opaque that it becomes, practically speaking, incapable of use;” or (3) “prison administrators thwart inmates from taking advantage of a grievance process through machination, misrepresentation, or intimidation.” Ross v. Blake, 578 U.S. 632, 642 (2016); see also Townsend v. Murphy, 898 F.3d 780, 783 (8th Cir. 2018). B. ADC’s Grievance Procedure

Administrative Directive 19-34 (“AD 19-34”) establishes a three-step procedure for exhausting administrative remedies in any ADC Unit. (Doc. 28-3.) A summary of that procedure is included in the Inmate Handbook, a full copy is available in the prison law library, and many of the requirements are included on the forms themselves. (Id. at § IV(C).) 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. (Id. at § IV(E)(1)). 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.” (Id. at § IV(E)(2)) (emphasis added.) Inmates are cautioned a

3 “[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)) (emphasis added.) And the grievance form reminds prisoners to include the “name of personnel involved.” (Id. at 20.) 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. (Id. § IV(E)(11) and (F)(1).) Third, an inmate who is dissatisfied with the Warden’s response, or who does not timely receive a response, must appeal within five working days to the “Chief Deputy/Deputy/Assistant Director.” (Id. § IV(F)(9)) And the response ends the grievance process. (Id.) C. Analysis Grievance Supervisor Terri Grigsby-Brown provided a declaration, under oath, and stated: During my review, I did not find any exhausted non-medical grievances that were filed between November 13, 2023, and January 21, 2025, pertaining to Inmate Foster’s claims in this lawsuit. In fact, from November 13, 2023, up until the date he filed this lawsuit on January 21, 2025, Inmate Foster did not specifically name or claim in any non-medical grievance that Aundrea Culclager had in any manner violated his constitutional rights.

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Related

Woodford v. Ngo
548 U.S. 81 (Supreme Court, 2006)
Jones v. Bock
549 U.S. 199 (Supreme Court, 2007)
Holden v. Hirner
663 F.3d 336 (Eighth Circuit, 2011)
Ross v. Blake
578 U.S. 632 (Supreme Court, 2016)
Jacob Townsend v. Terry Murphy
898 F.3d 780 (Eighth Circuit, 2018)

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Bluebook (online)
Foster v. Culclager, Counsel Stack Legal Research, https://law.counselstack.com/opinion/foster-v-culclager-ared-2025.