Joshua Burns v. P FNU Croteau, et al.

2020 DNH 195
CourtDistrict Court, D. New Hampshire
DecidedNovember 6, 2020
Docket19-cv-007-LM
StatusPublished
Cited by1 cases

This text of 2020 DNH 195 (Joshua Burns v. P FNU Croteau, et al.) is published on Counsel Stack Legal Research, covering District Court, D. New Hampshire primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Joshua Burns v. P FNU Croteau, et al., 2020 DNH 195 (D.N.H. 2020).

Opinion

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF NEW HAMPSHIRE

Joshua Burns

v. Civil No. 19-cv-007-LM Opinion No. 2020 DNH 195 P FNU Croteau, et al.

ORDER

Plaintiff Joshua Burns, an incarcerated prisoner represented by counsel,

brings this civil rights action against Corporal Jason Croteau, Sergeant Dwayne

Sweatt, and an unspecified number of Doe defendants. All defendants are

corrections officers employed by the New Hampshire Department of Corrections

(the “DOC”) at the Northern Correctional Facility for Men in Berlin, New

Hampshire (“NCF Berlin”), and all are sued in their individual capacities only.

Burns alleges that after he refused to obey an inappropriate order, Croteau and

Sweatt beat him severely, causing serious injury. He further alleges that the Doe

defendants failed to intervene to protect him. Arising out of that incident, Burns

asserts Croteau’s and Sweatt’s liability under 42 U.S.C. § 1983 for violation of his

Eighth Amendment right to freedom from excessive force while incarcerated, and

under New Hampshire common law for assault and battery. In addition, Burns

asserts the Doe defendants’ liability under Section 1983 for failure to intervene.

Defendants move for summary judgment, arguing that Burns failed to

exhaust his administrative remedies before bringing this action, thus depriving this court of authority to consider his claims under the Prison Litigation Reform Act (the

“PLRA”). Burns objects, arguing that he exhausted the administrative procedures

available to him. Burns submitted a grievance of the incident but did not use the

required form. In addition, he did not pursue the grievance procedure through its

second and third steps, as is mandatory under the administrative process.

Although Burns argues that proper exhaustion of the procedures was impossible

both because he did not understand them and because he was transferred to a non-

DOC facility a few days after the incident occurred, as a matter of law these issues

did not render the administrative procedures effectively unavailable. The court

therefore agrees with defendants that Burns failed to exhaust available

administrative remedies as required under the PLRA.

THE PRISON LITIGATION REFORM ACT

Under the Prison Litigation Reform Act, incarcerated plaintiffs must exhaust

all available administrative remedies before bringing any federal action in respect

to prison conditions. 42 U.S.C. § 1997e(a). For purposes of the PLRA, a civil rights

action arising out of an isolated episode of unlawful misconduct by prison officials

constitutes a challenge to prison conditions. See Porter v. Nussle, 534 U.S. 516, 532

(2002). Under the PLRA, federal courts lack discretion to consider any claim

challenging prison conditions unless the exhaustion requirement has been satisfied,

without regard to whether the remedy sought in the federal action was available

under the institution’s administrative procedure. See id. at 524 (citing Booth v.

2 Churner, 532 U.S. 731, 739, 740 n. 5 (2001)). Requiring inmates to exhaust

administrative remedies before suing in federal court “allows prison officials an

opportunity to resolve disputes concerning the exercise of their responsibilities

before being haled into court.” Jones v. Bock, 549 U.S. 199, 204 (2007).

“[I]t is the prison’s requirements, and not the PLRA, that define the

boundaries of proper exhaustion.” Id. at 218. The Supreme Court has specified that

“the PLRA exhaustion requirement requires proper exhaustion” of all

administrative procedures in use at the prison. Woodford v. Ngo, 548 U.S. 81, 93

(2006). “[P]roper exhaustion” refers to “using all steps that the agency holds out,

and doing so properly (so that the agency addresses the issues on the merits).” Id.

at 90 (citation omitted; emphasis original). The Woodford court reasoned that to

require less than complete and proper exhaustion, including compliance with

deadlines and all procedural requisites, would permit prisoners to render the PLRA

exhaustion requirement “wholly ineffective.” Id. at 95. That is, prisoners could

default in the performance of administrative requirements and then claim

exhaustion by virtue of their own procedural default. See id.

Notwithstanding the foregoing, prisoners are only required to exhaust those

administrative remedies that are effectively available to them. A prisoner who fails

to follow a prison’s administrative grievance procedure through to its final step has

nevertheless exhausted available administrative remedies where: (1) remedies are

functionally unavailable because prison officials are “unable or consistently

unwilling to provide any relief to aggrieved inmates;” (2) the administrative

3 procedure is too confusing, baroque, or flawed to be navigated to completion by a

reasonable prisoner; or (3) prison officials thwart prisoners’ efforts to exhaust

available administrative remedies “through machination, misrepresentation, or

intimidation.” Ross v. Blake, 136 S. Ct. 1850, 1859-1860 (2016) (citing Booth, 532

U.S. at 736, 738).

Claims that have not been exhausted are subject to dismissal. See Medina-

Claudio v. Rodríguez-Mateo, 292 F.3d 31, 36 (1st Cir. 2002). Defendants bear the

burden to show both that administrative remedies were available and that the

prisoner failed to exhaust them. See, e.g., Fuqua v. Ryan, 890 F.3d 838, 844 (9th

Cir. 2018). If defendants make that showing, the burden shifts to the prisoner to

come forward with evidence showing that the existing and generally available

administrative remedies were effectively unavailable to him. See id.

The First Circuit has not addressed whether factual issues regarding

exhaustion are the province of the judge or the jury. However, all the circuit courts

that have considered the question have held that it is for the court rather than a

jury to resolve such issues. See, e.g., Albino v. Baca, 747 F.3d 1162, 1170-1171 (9th

Cir. 2014) (“disputed factual questions relevant to exhaustion should be decided by

the judge, in the same manner a judge rather than a jury decides disputed factual

questions relevant to jurisdiction and venue”); see also Lee v. Willey, 789 F.3d 673,

678 (6th Cir. 2015); Small v. Camden Cty., 728 F.3d 265, 271 (3rd Cir. 2013); Messa

v. Goord, 652 F.3d 305, 309 (2nd Cir. 2011); Dillon v. Rogers, 596 F.3d 260, 271 (5th

Cir. 2010); Pavey v.

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Burns v. Croteau
D. New Hampshire, 2020

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