Jason J. Spikes v. Louisiana Department of Public Safety and Corrections

CourtLouisiana Court of Appeal
DecidedFebruary 24, 2023
Docket2022CA0880
StatusUnknown

This text of Jason J. Spikes v. Louisiana Department of Public Safety and Corrections (Jason J. Spikes v. Louisiana Department of Public Safety and Corrections) is published on Counsel Stack Legal Research, covering Louisiana Court of Appeal primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Jason J. Spikes v. Louisiana Department of Public Safety and Corrections, (La. Ct. App. 2023).

Opinion

NOT DESIGNATED FOR PUBLICATION

STATE OF LOUISIANA

COURT OF APPEAL

FIRST CIRCUIT

2022 CA 0880

JASON J. SPIKES

VERSUS

LOUISIANA DEPARTMENT OF PUBLIC SAFETY AND

r Pt4/( CORRECTIONS

DATE of JUDGMENT:• FEB 2 4 2023

ON APPEAL FROM THE NINETEENTH JUDICIAL DISTRICT COURT PARISH OF EAST BATON ROUGE, STATE OF LOUISIANA NUMBER 715967, SECTION 32

HONORABLE ROBERT MORRISON, JUDGE AD HOC

Jason Jarrell Spikes Plaintiff A - ppellant Angie, Louisiana Pro Se

Jonathan R. Vining Counsel for Defendant -Appellee Baton Rouge, Louisiana Louisiana Department of Public Safety and Corrections

BEFORE: THERIOT, CHUTZ, AND RESTER, JJ.

Disposition: AFFIRMED. Chutz, J.

Jason Jarrell Spikes, an inmate in the custody of the Louisiana Department of

Public Safety and Corrections (" DPSC"), appeals a district court judgment

dismissing, without prejudice, his petition for judicial review of Administrative

Remedy Procedure ( ARP) No. RCC -2021- 591 for lack of jurisdiction due to his

failure to exhaust administrative remedies. We affirm.

4n September 20, 2021, Spikes filed ARP No. RCC -2021- 591. It appears he

claimed therein that he was beaten by several correctional officers, resulting in

injuries including a swollen eye and a broken jaw requiring hospitalization. Spikes

alleged he was also subsequently threatened with further bodily harm by high-

ranking correctional officers. Spikes sought civil, criminal, and administrative

relief, as well as payment of his medical bills.

After receiving ARP No. RCC -2021- 591, DPSC informed Spikes the ARP

was being placed on " backlog" because he already had another ARP pending in the

system. Spikes was further informed he could withdraw the previously pending

ARP if he wished to have ARP No. RCC -2021- 0591 handled immediately. 4n

February 14, 2022, Spikes filed a petition for judicial review in the 19th Judicial

District Court seeking review of ARP No. RCC -2021- 591. In the petition, Spikes

made no reference to any final agency decision on ARP No. RCC -2021- 591. Upon

review, a 19th JDC commissioner' concluded Spikes' petition failed to comply with

the district court' s local rules, which required he file written proof that he had

exhausted his administrative remedies with regard to the ARP in accordance with

La. R.S. 15: 1172 and 1184. Accordingly, the commissioner issued an order to

Spikes on February 16, 2022, to submit such proof within 15 days and informed him

the failure to do so could result in dismissal of the suit. In response, Spikes submitted

1 See La. R.S. 13: 711 and 713. 2 a letter from DPSC establishing that after ARP No. RCC -2021- 591 was received and

assigned a number, DPSC placed it on backlog pending the completion of Spikes'

other ARPs. In the letter, DPSC further informed Spikes that ARP No. RCC -2021-

591 would be accepted once the other " active" ARP he had in the system was

exhausted.

On March 15, 2022, the commissioner issued a screening recommendation to

the district court in accordance with La. R.S. 15: 1178 and 1184- 88. Therein, the

commissioner determined the district court lacked subject matter jurisdiction to

review ARP No. RCC -2021- 591 because Spikes failed to exhaust his administrative

remedies prior to instituting suit, i.e., his suit was filed prematurely. Thus, in

accordance with La. R.S. 15: 1178, the commissioner recommended Spikes' suit be

dismissed without prejudice.

In an apparent response to the commissioner' s screening recommendation,

Spikes filed a motion requesting his suit be held open until he had exhausted his

administrative remedies. He attached a letter to the motion showing DPSC had

responded to his request that ARP No. RCC -2021- 591 " be answered" by informing

him ARP No. RCC- 2021- 591was backlogged and had not yet been accepted because

his prior ARP had not been exhausted at that time.

On May 16, 2022, the district court signed a judgment adopting the

recommendation of the commissioner and dismissing, without prejudice, Spikes'

petition for judicial review of ARP No. RCC -2021- 591 for lack of subject matter

jurisdiction based on his failure to exhaust administrative remedies in accordance

with La. R.S. 15: 1172( C). Spikes appealed this judgment.

The Corrections Administrative Remedy Procedure (" CARP"), La. R. S.

15: 1171- 1179, provides that DPSC may adopt an administrative remedy procedure

for receiving, hearing, and disposing of any and all complaints and grievances by

offenders against the state, the governor, and/ or DPSC or its employees. The

3 adopted procedures are the exclusive remedy for handling the complaints and

grievances to which they apply. La. R. S. 15: 1171; Spikes v Louisiana Department

ofPuh. Safety & Corrections, 22- 0504 ( La. App. 1st Cir. 11/ 4/ 22), So. 3d ,

2022 WL 16705741, at * 2.

Pursuant to the rules and regulations promulgated by DPSC, offenders must

exhaust a two-step ARP before they can proceed with a suit in federal or state court.

See La. R.S. 15. 1176; LAC 22: I.325( F)( 3)( a)( viii). If an offender fails to exhaust

available administrative remedies, the courts lack subject matter jurisdiction to

review the claim. Spikes, So. 3d at , 2022 WL 16705741, at * 2; Dickens v

Louisiana Correctional lnstitute for Women, 11 - 0 176 ( La. App. 1 st Cir. 9/ 14/ 11),

77 So. 3d 70, 74- 75. Under LAC 22. I. 325( E), exhaustion of available administrative

remedies " only occurs when an offender files a timely and procedurally proper

request for remedy, which after it is accepted, is addressed on the merits at Doth the

first and second step." ( Emphasis added.)

In the event an offender submits multiple ARP requests during the review of

a previous ARP request, the subsequent ARP requests will be backlogged and set

aside for handling at such time as the ARP request currently in the system has been

exhausted at the second step or until time limits to proceed from the first step to the

second step have lapsed. LAC 22: I.325( F)( 3)( a)( ix). This regulation applies to

situations where an ARP request for relief has been accepted at the initial step of the

ARP and a distinct, subsequent ARP request for relief is filed. Spikes, So. 3d at

2022 WL 16705741, at * 2; Vincent v Stalder, 04- 1750 ( La. App. 1st Cir.

9/ 23/ 05), 923 So.2d 108, 110. Additionally, the time limits provided for DPSC to

respond to an offender' s ARP request for relief do not operate to prevent DPSC from

backlogging multiple requests for administrative relief. The time periods provided

by DPSC' s regulations for handling ARPs apply only to ARP claims accepted and

M processed by DPSC. 2 Spikes, So. 3d at , 2022 WL 16705741, at * 2; Vincent,

923 So. 2d at 110- 11. Moreover, DPSC' s regulation regarding backlogging of

multiple claims is a valid and reasonable exercise of the authority granted to DPSC.

Id.

In the instant case, the record reflects Spikes' ARP No. RCC -2021- 591 was

placed on backlog when it was received by DPSC on September 20, 2021, because

he already had a prior ARP being processed. Nevertheless, without waiting for ARP

No. RCC -2021- 591 to be accepted by DPSC and processed, Spikes filed this petition

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Related

Dickens v. Louisiana Correctional Institute for Women
77 So. 3d 70 (Louisiana Court of Appeal, 2011)
Vincent v. Stalder
923 So. 2d 108 (Louisiana Court of Appeal, 2005)

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