James P. Abrams v. David Paul, Warden, et al.

CourtDistrict Court, E.D. Kentucky
DecidedMay 19, 2026
Docket5:25-cv-00285
StatusUnknown

This text of James P. Abrams v. David Paul, Warden, et al. (James P. Abrams v. David Paul, Warden, et al.) is published on Counsel Stack Legal Research, covering District Court, E.D. Kentucky primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
James P. Abrams v. David Paul, Warden, et al., (E.D. Ky. 2026).

Opinion

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF KENTUCKY CENTRAL DIVISION LEXINGTON JAMES P. ABRAMS, ) ) Plaintiff, ) Case No. 5:25-cv-00285-GFVT ) v. ) MEMORANDUM OPINION ) & DAVID PAUL, WARDEN, et al., ) ORDER ) Defendants. )

*** *** *** *** This matter is pending for consideration of the defendants’ motion to dismiss [R. 41], which the Court converted into a motion for summary judgment [R. 45]. Having carefully considered the parties’ arguments and the applicable law, the Court will dismiss the plaintiff’s claims without prejudice based on his failure to exhaust administrative remedies. I James P. Abrams is an inmate at the Federal Medical Center in Lexington, Kentucky (“FMC Lexington”). Proceeding without counsel, Abrams filed a civil rights complaint alleging that officials at FMC Lexington were deliberately indifferent to his serious medical needs in violation of the Eighth Amendment. On February 9, 2026, the defendants filed a motion to dismiss arguing, inter alia, that Abrams failed to exhaust administrative remedies as required by 42 U.S.C. § 1997e. [R. 41]. Abrams filed a timely response opposing the defendants’ motion. [R. 42]. The Court subsequently determined that the defendants’ motion must be viewed as a motion for summary judgment since the defendants rely on material outside the pleadings. See Fed. R. Civ. P. 12(d). The Court invited Abrams to file an additional response presenting information and/or arguments related to his exhaustion of administrative remedies. [R. 43]. Abrams filed a response brief on April 28, 2026, making this matter ripe for review. II Federal law requires a prisoner to fully exhaust his available administrative remedies before filing suit to assert a civil claim regarding the conditions of his confinement. See 42 U.S.C. § 1997e(a); Jones v. Bock, 549 U.S. 199, 211 (2007) (“There is no question that

exhaustion is mandatory under the PLRA and that unexhausted claims cannot be brought in court.”). There is a multi-tiered administrative remedy process (“ARP”) within the BOP. If a matter cannot be resolved informally via a so-called BP-8 Form, the prisoner must file a BP-9 Administrative Remedy Request Form with the Warden, who has 20 days to respond. See 28 C.F.R. §§ 542.14(a) and 542.18. If the prisoner is not satisfied with the Warden’s response, he may use a BP-10 Form to appeal to the applicable Regional Director, who has 30 days to respond. See 28 C.F.R. §§ 542.15 and 542.18. If the prisoner is not satisfied with the Regional Director’s response, he may use a BP-11 Form to appeal to the General Counsel, who has 40 days to respond. See 28 C.F.R. §§ 542.15 and 542.18. To satisfy the exhaustion requirement, the inmate must fully comply with the relevant agency’s “deadlines and other critical procedural

rules.” Woodford v. Ngo, 548 U.S. 81, 90 (2006). Summary judgment is proper where there is no genuine issue of material fact, and the moving party is entitled to judgment as a matter of law. See Fed. R. Civ. P. 56(a). In considering a motion for summary judgment, the court views the evidence and draws all reasonable inferences in favor of the non-moving party. See Scott v. Harris, 550 U.S. 372, 378 (2007); Shumate v. City of Adrian, Mich., 44 F.4th 427, 438 (2022). The Court does not weigh the evidence or make credibility determinations. See Anderson v. Liberty Lobby, Inc., 477 U.S. 242, 255 (1986); Adams v. Metiva, 31 F.3d 375, 378 (6th Cir. 1994). An inmate's failure to exhaust his administrative remedies is an affirmative defense that the defendants have the burden to plead and prove by a preponderance of the evidence. Lamb v. Kendrick, 52 F.4th 286, 292 (6th Cir. 2022). See also Morgan v. Trierweiler, 67 F.4th 362, 366 (6th Cir. 2023) (“Because defendants carry the burden of proof for exhaustion, they bear an

initial summary judgment burden that is higher in that they must show that the record contains evidence satisfying their burden of persuasion and that no reasonable jury would be free to disbelieve it.”) (internal quotation marks and citations omitted). Summary judgment is appropriate in this context only if “there is no genuine dispute of material fact that the plaintiff failed to exhaust.” Risher v. Lappin, 639 F.3d 236, 240 (6th Cir. 2011)). In support of their motion, the defendants tendered the declaration of BOP Paralegal Specialist Misty Shaw. [R. 41-1]. Shaw reports: Abrams has submitted a total of nine administrative remedy requests or appeals. Of those nine submissions, three submissions requested compassionate release. The remaining six submissions involved staff retaliation and shackles causing injuries to Abrams’ legs, or medical retaliation and Abrams’ medical duty status. All six submissions failed to comply with the requirements for submitting a request or appeal and were rejected. The grounds for rejection of each submission are as follows:

Remedy ID No. 1241736-R1 was submitted on May 22, 2025, and was rejected on May 23, 2025, as it was submitted at the wrong level (WRL), should be submitted at the institutional level (INS), it was not a sensitive issue (SEN), and it was not submitted on the proper form (FRM).

Remedy ID No. 1241736-R2 was submitted on June 10, 2025, and rejected on the same date, as it was submitted at the wrong level (WRL), should be submitted at the institutional level (INS), it was not a sensitive issue (SEN), it was not submitted on the proper form (FRM), it had multiple continuation pages (ONE). Remedy ID No. 1241736-R3 was submitted on June 12, 2025, and rejected on June 12, 2025, as the Warden’s Response provided with the appeal did not match the issue in the appeal but matched the issue in Remedy ID No. 1236118-F1.

Remedy ID No. 1241736-F4 was submitted on June 30, 2025, and was rejected on July 2, 2025, as it was submitted at the wrong level (WRL), should be submitted at the institutional level (INS), it was not a sensitive issue (SEN), and it addressed more than one remedy (MLT). Abrams was advised that he could only address one remedy per appeal (OTH).

Remedy ID No. 1241736-F5 was submitted on September 2, 2025, and was rejected on September 4, 2025, as it was submitted at the wrong level (WRL), should be submitted at the institutional level (INS), and it was not a sensitive issue (SEN).

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Related

Anderson v. Liberty Lobby, Inc.
477 U.S. 242 (Supreme Court, 1986)
Woodford v. Ngo
548 U.S. 81 (Supreme Court, 2006)
Scott v. Harris
550 U.S. 372 (Supreme Court, 2007)
Jones v. Bock
549 U.S. 199 (Supreme Court, 2007)
Gene Autrey Adams v. Paul Metiva
31 F.3d 375 (Sixth Circuit, 1994)
Risher v. Lappin
639 F.3d 236 (Sixth Circuit, 2011)
Robert Shumate v. City of Adrian, Mich.
44 F.4th 427 (Sixth Circuit, 2022)
Toby Lamb, II v. Brant Kendrick
52 F.4th 286 (Sixth Circuit, 2022)
Asheton S. Morgan v. Tony Trierweiler
67 F.4th 362 (Sixth Circuit, 2023)
Perttu v. Richards
605 U.S. 460 (Supreme Court, 2025)

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Bluebook (online)
James P. Abrams v. David Paul, Warden, et al., Counsel Stack Legal Research, https://law.counselstack.com/opinion/james-p-abrams-v-david-paul-warden-et-al-kyed-2026.