Murdock v. Moore

CourtDistrict Court, W.D. North Carolina
DecidedMay 27, 2025
Docket5:24-cv-00119
StatusUnknown

This text of Murdock v. Moore (Murdock v. Moore) is published on Counsel Stack Legal Research, covering District Court, W.D. North Carolina primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Murdock v. Moore, (W.D.N.C. 2025).

Opinion

INTHE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF NORTH CAROLINA STATESVILLE DIVISION 5:24-cv-00119-MR-SCR

AJANAKU MURDOCK, ) ) Plaintiff, ) ) vs. ) ) MEMORANDUM OF ) DECISION AND ORDER STEPHANIE CURTIS, ) ) Defendant. ) _______________________________ )

THIS MATTER is before the Court on the Defendant’s Motion to Dismiss [Doc. 25]; the Magistrate Judge’s Memorandum and Recommendation regarding the disposition of Defendant’s Motion to Dismiss [Doc. 29]; the Plaintiff’s “Response to Motion to Dismiss Memorandum and Recommendation” [Doc. 31], which the Court construes as Plaintiff’s Objection to the Recommendation; and the Defendant’s Reply to Plaintiff’s Objections to the Magistrate’s Memorandum and Recommendation [Doc. 32]. I. PROCEDURAL BACKGROUND Pro se Plaintiff Ajanaku Murdock (“Plaintiff”) is a prisoner of the State of North Carolina currently incarcerated at Central Prison in Raleigh, North Carolina. On May 7, 2024, he filed this action pursuant to 42 U.S.C. § 1983 seeking relief for two unrelated alleged uses of excessive force by two sets

of Defendants, all identified as Correctional Officers at Alexander Correctional Institution (“Alexander”). [Doc. 1]. After Plaintiff’s Complaint failed initial review [Doc. 6], Plaintiff filed an Amended Complaint naming

Defendants Michael Moore, II, and Stephanie Curtis as Defendants, alleging that, on March 7, 2023, they used excessive force on Plaintiff in violation of his Eighth Amendment rights1 [Doc. 7]. Plaintiff’s Amended Complaint passed initial review [Doc. 9], and the Court later dismissed Defendant

Moore without prejudice for Plaintiff’s failure to show good cause for the failure to timely serve him [Docs. 22, 28]. On November 29, 2024, Defendant Curtis moved pursuant to Federal

Rule of Civil Procedure 12(b)(6) to dismiss Plaintiff’s Complaint for his failure to exhaust administrative remedies pursuant to the Prison Litigation Reform Act (“PLRA”), 42 U.S.C. § 1997e(a), before filing this action. [Doc. 26]. The Honorable Susan C. Rodriguez, United States Magistrate Judge, entered an

order in accordance with Roseboro v. Garrison, 528 F.2d 309 (4th Cir. 1975),

1 At this time, Plaintiff also filed a new separate Complaint against the other set of Defendants, FNU Baers, FNU Adkins, FNU Emig, and FNU Sigmon, related to a separate alleged use of excessive force on December 12, 2023. [Murdock v. Adkins, Case No. 5:24-cv-00163-KDB, Doc. 1]. notifying Plaintiff of his right to respond to Defendant’s motion within 30 days and warning Plaintiff that his failure to timely respond would “likely lead to

the granting of relief that Defendant seeks.” [Doc. 27]. Plaintiff nonetheless failed to respond to Defendant’s motion. Pursuant to 28 U.S.C. § 636(b) and the Standing Orders of Designation

of this Court, Judge Rodriguez was designated to consider the Defendant’s motion and to submit a recommendation regarding its disposition. On February 24, 2025, nearly two months after Plaintiff’s deadline to respond expired, Judge Rodriguez entered a Memorandum and Recommendation in

which she recommended that (1) the Court should dismiss this action with prejudice for Plaintiff’s abandonment of his claim [Doc. 29 at 4, 8], and (2) even if Plaintiff had not abandoned his claim, the Court should dismiss

Plaintiff’s claim without prejudice for failure to exhaust his administrative remedies [Doc. 29 at 8]. Plaintiff timely filed Objections [Doc. 31], to which the Defendant has responded [Doc. 32]. Having been fully briefed, this matter is ripe for disposition.

II. STANDARD OF REVIEW

A. Standard of Review Applicable to a Magistrate Judge’s Proposed Findings and Recommendation

The Federal Magistrate Act requires a district court to “make a de novo determination of those portions of the report or specific proposed findings or recommendations to which objection is made.” 28 U.S.C. § 636(b)(1). In order “to preserve for appeal an issue in a magistrate judge’s report, a party

must object to the finding or recommendation on that issue with sufficient specificity so as reasonably to alert the district court of the true ground for the objection.” United States v. Midgette, 478 F.3d 616, 622 (4th Cir. 2007).

The Court is not required to review, under a de novo or any other standard, the factual or legal conclusions of the magistrate judge to which no timely objections have been raised. Thomas v. Arn, 474 U.S. 140, 150 (1985). Additionally, the Court need not conduct a de novo review where a party

makes only “general and conclusory objections that do not direct the court to a specific error in the magistrate’s proposed findings and recommendations.” Orpiano v. Johnson, 687 F.2d 44, 47 (4th Cir. 1982). When reviewing pro

se objections to a magistrate judge’s recommendation, however, “district courts must review de novo any articulated grounds to which the litigant appears to take issue.” Elijah v. Dunbar, 66 F.4th 454, 460-61 (4th Cir. 2023) (citing Martin v. Duffy, 858 F.3d 239, 245-46 (4th Cir. 2017)). “Such a

requirement advances district court’s obligation to liberally construe pro se objections while maintaining constitutional limitations on a magistrate’s authority.” Id. at 461. B. Exhaustion The PLRA requires a prisoner to exhaust his administrative remedies

before filing a section 1983 action. 42 U.S.C. § 1997e(a). The PLRA provides, in pertinent part, that “[n]o 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.” Id. The PLRA’s exhaustion requirement applies to all inmate suits about prison life. Porter v. Nussle, 534 U.S. 516, 532 (2002). There is “no question that

exhaustion is mandatory under PLRA and that unexhausted claims cannot be brought in court.” Jones v. Bock, 549 U.S. 199, 211 (2007) (citing Porter, 534 U.S. at 524). The PLRA requires “proper” exhaustion, which means

“using all steps that the agency holds out, and doing so properly (so that the agency addresses the issues on the merits).” Woodford v. Ngo, 548 U.S. 81, 90 (2006) (quoting Pozo v. McCaughtry, 286 F.3d 1022, 1024 (7th Cir. 2002)).

An inmate, however, is not required to affirmatively show exhaustion in his complaint. See Bock, 549 U.S. at 216.

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Thomas v. Arn
474 U.S. 140 (Supreme Court, 1986)
Porter v. Nussle
534 U.S. 516 (Supreme Court, 2002)
Doe v. Chao
540 U.S. 614 (Supreme Court, 2004)
Woodford v. Ngo
548 U.S. 81 (Supreme Court, 2006)
Jones v. Bock
549 U.S. 199 (Supreme Court, 2007)
United States v. Sean Howell
231 F.3d 615 (Ninth Circuit, 2000)
United States v. Nicholas Omar Midgette
478 F.3d 616 (Fourth Circuit, 2007)
Moore v. Bennette
517 F.3d 717 (Fourth Circuit, 2008)
Marqus Stevenson v. City of Seat Pleasant, MD
743 F.3d 411 (Fourth Circuit, 2014)
Ross v. Blake
578 U.S. 632 (Supreme Court, 2016)
Anthony Martin v. Susan Duffy
858 F.3d 239 (Fourth Circuit, 2017)
Torrey F. Wilcox v. Betty Brown
877 F.3d 161 (Fourth Circuit, 2017)
Doe v. Chao
306 F.3d 170 (Fourth Circuit, 2002)
Caldwell v. Jackson
831 F. Supp. 2d 911 (M.D. North Carolina, 2010)
Matthew Griffin v. Nadine Bryant
56 F.4th 328 (Fourth Circuit, 2022)
Larone Elijah v. Richard Dunbar
66 F.4th 454 (Fourth Circuit, 2023)

Cite This Page — Counsel Stack

Bluebook (online)
Murdock v. Moore, Counsel Stack Legal Research, https://law.counselstack.com/opinion/murdock-v-moore-ncwd-2025.