Michael Latroy Hall v. Steve Hinkley

District Court, W.D. Michigan·Decided September 3, 2026·No. 1:25-cv-00198·Unknown

Opinion

UNITED STATES DISTRICT COURT WESTERN DISTRICT OF MICHIGAN SOUTHERN DIVISION

MICHAEL LATROY HALL,

Plaintiff, Hon. Phillip J. Green

v. Case No. 1:25-cv-00198

STEVE HINKLEY,

Defendant. ____________________________________/

OPINION

This matter is before the Court on Defendants’ Motion for Summary Judgment. (ECF No. 11). For the reasons stated herein, Defendant’s motion will be granted and this action terminated. BACKGROUND The events about which Plaintiff complains occurred at the Calhoun County Correctional Facility (CCCF) in Battle Creek, Calhoun County, Michigan. (ECF No. 1). Plaintiff sued several CCCF personnel in their individual and official capacities. (Id.). The Court permitted Plaintiff to proceed as a pauper, and, upon screening under 28 U.S.C. § 1915(e)(2), dismissed all claims except for Plaintiff’s official capacity claim under the ADA against Defendant Hinkley. (ECF Nos. 4 and 5). Plaintiff was booked into CCCF on July 17, 2024. (ECF No. 1-1, PageID.19). In his complaint, Plaintiff alleges that, on July 30, 2024, he was placed in a top bunk.

-1- (ECF No. 1, PageID.7). On August 2, 2024, Plaintiff wrote a kite to medical through a kiosk, stating “[n]eed my bottom bunk detail for my back problems from the car accident on 3/10/24.” (ECF No. 12-3, PageID.124). Nurse Boyer responded, “You will need to

talk to the provider about this at your appointment.” (Id.). Plaintiff alleges that he received his accommodation paperwork the following morning. (ECF No. 1, PageID.7). A “medical special accommodation” form dated August 3, 2024, stated that Plaintiff “must receive” a bottom bunk in main floor housing until his release. (ECF No. 1-1, PageID.18; ECF No. 12-3, PageID.96). The authorizing nurse noted “order wrote 7/17/24.” (Id.). Plaintiff alleges he slept four nights in a top bunk—July 30, 2024 to the morning of August 3, 2024—causing “extreme pain to [his] left shoulder (surgery on

6/5/24), back pain[,] and right ankle pain.” (ECF No. 1, PageID.7). Defendant Hinkley filed a dispositive motion on both exhaustion grounds and on the merits. (ECF No. 11). Plaintiff failed to respond to Defendant’s motion. The Court finds that oral argument is unnecessary. See W.D. MICH. LCIVR 7.2(d). SUMMARY JUDGMENT STANDARD

Summary judgment “shall” be granted “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). Whether a fact is “material” depends on “whether its resolution might affect the outcome of the case.” Harden v. Hillman, 993 F.3d 465, 474 (6th Cir. 2021).

-2- A party moving for summary judgment can satisfy its burden by demonstrating that the non-moving party, “having had sufficient opportunity for discovery, has no evidence to support an essential element of his or her case.” Minadeo v. ICI Paints, 398

F.3d 751, 761 (6th Cir. 2005). Once the moving party makes this showing, the non- moving party “must identify specific facts that can be established by admissible evidence, which demonstrate a genuine issue for trial.” Amini v. Oberlin College, 440 F.3d 350, 357 (6th Cir. 2006). The existence of a mere “scintilla of evidence” in support of the non- moving party’s position, however, is insufficient. Daniels v. Woodside, 396 F.3d 730, 734-35 (6th Cir. 2005). While the Court must view the evidence in the light most favorable to the non-

moving party, that party “must do more than simply show that there is some metaphysical doubt as to the material facts.” Amini, 440 F.3d at 357. The non-moving party “may not rest upon [his] mere allegations,” but must instead present “significant probative evidence,” establishing that “there is a genuine issue for trial.” Pack v. Damon Corp., 434 F.3d 810, 813-14 (6th Cir. 2006). Likewise, the non-moving party cannot merely “recite the incantation, ‘credibility,’ and have a trial on the hope that a

jury may disbelieve factually uncontested proof.” Fogerty v. MGM Group Holdings Corp., Inc., 379 F.3d 348, 353-54 (6th Cir. 2004). Accordingly, summary judgment is appropriate “against a party who fails to make a showing sufficient to establish the existence of an element essential to that party’s case, and on which that party will bear the burden of proof at trial.” Daniels, 396 F.3d

-3- at 735. Stated differently, the “ultimate question is whether the evidence presents a sufficient factual disagreement to require submission of the case to the jury, or whether the evidence is so one-sided that the moving parties should prevail as a matter of law.”

Harden, 993 F.3d at 474. ANALYSIS Because Plaintiff was incarcerated at CCCF at the time he filed the instant action, he is subject to the requirements of the Prison Litigation Reform Act (PLRA). See 42 U.S.C. S 1997e(a); see also Napier v. Laurel Cnty., Ky., 636 F.3d 218, 222 (6th Cir. 2011) (noting that the PLRA applies to an inmate “in any jail, prison, or other correctional

facility”). In order to “allow prison officials ‘a fair opportunity’ to address grievances on the merits, to correct prison errors that can and should be corrected and to create an administrative record for those disputes that eventually end up in court,” Reed-Bey v. Pramstaller, 603 F.3d 322, 324 (6th Cir. 2010) (citing Woodford v. Ngo, 548 U.S. 81, 94- 95 (2006)), the PLRA requires 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); 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.”).

-4- To exhaust administrative remedies, an incarcerated person must take “advantage of each step the prison holds out for resolving the claim internally” and “follow[ ] the ‘critical procedural rules’ of the prison’s grievance process.” Reed-Bey, 603

F.3d at 324 (citing Woodford, 548 U.S. at 94-95). “The level of detail necessary in a grievance to comply with the grievance procedures will vary from system to system and claim to claim, but it is the prison’s requirements, and not the PLRA, that define the boundaries of proper exhaustion.” Jones, 549 U.S. at 218. The failure to exhaust administrative remedies is “an affirmative defense under the PLRA,” which the defendant bears the burden of establishing. Id. at 216. CCCF’s grievance policy requires that inmates first “[t]ry to informally resolve the

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Michael Latroy Hall v. Steve Hinkley, (W.D. Mich. 2026).

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Related

Reed-Bey v. Pramstaller
603 F.3d 322 (Sixth Circuit, 2010)
Woodford v. Ngo
548 U.S. 81 (Supreme Court, 2006)
Jones v. Bock
549 U.S. 199 (Supreme Court, 2007)
Napier v. Laurel County
636 F.3d 218 (Sixth Circuit, 2011)
Fogerty v. Mgm Group Holdings Corp.
379 F.3d 348 (Sixth Circuit, 2004)
Saeid B. Amini v. Oberlin College
440 F.3d 350 (Sixth Circuit, 2006)
Daniels v. Woodside
396 F.3d 730 (Sixth Circuit, 2005)
John Harden v. Keith Hillman
993 F.3d 465 (Sixth Circuit, 2021)