Isom Hamilton v. Jennifer Sierminski

District Court, E.D. Michigan·Decided February 11, 2026·No. 2:24-cv-12280·Unknown

Opinion

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF MICHIGAN SOUTHERN DIVISION

ISOM HAMILTON,

Plaintiff, Case No. 2:24-cv-12280 District Judge Susan K. DeClercq v. Magistrate Judge Anthony P. Patti

JENNIFER SIERMINSKI,

Defendant.

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MAGISTRATE JUDGE’S REPORT AND RECOMMENDATION TO DENY WITHOUT PREJUDICE DEFENDANT SIERMINSKI’S MOTION FOR SUMMARY JUDGMENT (ECF NO. 16) I. RECOMMENDATION: The Court should DENY WITHOUT PREJUDICE Defendant’s motion for summary judgment. (ECF No. 16.) II. REPORT: A. Background Plaintiff Isom Hamilton, a state prisoner, initiated this action in pro per on September 3, 2024 against Defendant Jennifer Sierminski based on an incident that occurred while Plaintiff was housed at the G. Robert Cotton Correctional Facility (“JCF”). (ECF No. 1.) Plaintiff makes many allegations against individuals who are not parties to this action, but with respect to the one defendant in this lawsuit, Plaintiff alleges that on September 301, 2021, two inmates jumped him and began kicking and punching him in full view of Defendant Sierminski and another

corrections officer. (ECF No. 1, PageID.40-42.) He contends that the assault continued for around 15-20 minutes and Defendant did nothing to help him and that, later, when she made her rounds, she deliberately ignored his calls for help as

he “lay on the floor dazed and dizzy from the assault.” (ECF No. 1, PageID.42.) He claims that he was retaliated against by the grievance coordinator, T. Cobb, by ignoring his request for a Step 2 and Step 3 appeal. (ECF No. 1, PageID.43.) His pro se complaint states that he brings a cause of action under 42 U.S.C. § 1983 for

a violation of his Eighth Amendment right to be free from cruel and unusual punishment based on Defendant Sierminski’s failure to intervene and stop the assault. (ECF No. 1, PageID.40.)

The matter was referred to me by Judge Susan K. DeClercq “for all pretrial proceedings, including a hearing and determination of all non−dispositive matters pursuant to 28 U.S.C. § 636(b)(1)(A) and/or a report and recommendation on all dispositive matters pursuant to 28 U.S.C. § 636(b)(1)(B).”

(ECF No. 10.)

1 Plaintiff first alleges the incident occurred on September “31,” 2021 (ECF No. 1, PageID.43), and later alleges the incident occurred on September 30, 2021 (ECF No. 1, PageID.53). Defendant Sierminski filed the instant motion for summary judgment on June 2, 2025, arguing that Plaintiff failed to exhaust his administrative remedies

before initiating the lawsuit and therefore she is entitled to summary judgment under Federal Rule of Civil Procedure 56. Plaintiff filed a response to the motion on July 2, 2025, 2 and Defendant filed a reply on July 18, 2025. (ECF Nos. 19, 22.)

B. Standard Under Federal Rule of Civil Procedure 56, “[t]he court shall grant summary judgment 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 fact is material if it might affect the outcome of the case under governing law. Anderson v. Liberty Lobby, Inc., 477 U.S. 242, 249 (1986). The Court “views the evidence, all facts, and any inferences that may be drawn from the facts

in the light most favorable to the nonmoving party.” Pure Tech Sys., Inc. v. Mt. Hawley Ins. Co., 95 F. App’x 132, 135 (6th Cir. 2004) (internal citations omitted). “The moving party has the initial burden of proving that no genuine issue of material fact exists . . . .” Stansberry v. Air Wis. Airlines Corp., 651 F.3d 482, 486

(6th Cir. 2011) (internal quotations omitted); cf. Fed. R. Civ. P. 56 (e)(2) (providing that if a party “fails to properly address another party’s assertion of

2 Plaintiff’s response was incorrectly docketed as a motion, but I have corrected that clerical error by text order. fact,” then the court may “consider the fact undisputed for the purposes of the motion.”). “Once the moving party satisfies its burden, ‘the burden shifts to the

nonmoving party to set forth specific facts showing a triable issue.’” Wrench LLC v. Taco Bell Corp., 256 F.3d 446, 453 (6th Cir. 2001) (quoting Matsushita Elec. Indus. Co. v. Zenith Radio Corp., 475 U.S. 574, 587 (1986)). Moreover, “the mere

existence of a scintilla of evidence that supports the nonmoving party’s claims is insufficient to defeat summary judgment.” Pack v. Damon Corp., 434 F.3d 810, 814 (6th Cir. 2006) (internal quotations and citations omitted). Summary judgment is appropriate if the evidence favoring the nonmoving

party is merely colorable or is not significantly probative. City Management Corp. v. United States Chem. Co., 43 F.3d 244, 254 (6th Cir. 1994). In other words, summary judgment is appropriate when “a motion for summary judgment is

properly made and supported and the nonmoving party fails to respond with a showing sufficient to establish an essential element of its case. . . .” Stansberry, 651 F.3d at 486 (citing Celotex Corp. v. Catrett, 477 U.S. 317, 322-23 (1986)). The fact that Plaintiff is pro se does not lessen his obligations under Rule 56.

Rather, “liberal treatment of pro se pleadings does not require lenient treatment of substantive law.” Durante v. Fairlane Town Ctr., 201 F. App’x 338, 344 (6th Cir. 2006). In addition, “[o]nce a case has progressed to the summary judgment stage, .

. . ‘the liberal pleading standards under Swierkiewicz [v. Sorema N.A., 534 U.S. 506, 512-13 (2002)] and [the Federal Rules] are inapplicable.’” Tucker v. Union of Needletrades, Indus. & Textile Employees, 407 F.3d 784, 788 (6th Cir. 2005)

(quoting Gilmour v. Gates, McDonald & Co., 382 F.3d 1312, 1315 (11th Cir. 2004)). C. Discussion

1. Failure to exhaust and PLRA cases Under the Prison Litigation Reform Act (PLRA), 42 U.S.C. § 1997e et seq., a prisoner may not bring an action “with respect to prison conditions under section 1983 of this title, or any other Federal law . . . until such administrative remedies

as are available are exhausted.” 42 U.S.C. § 1997e(a).

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