Parkins v. Barden

CourtDistrict Court, E.D. Arkansas
DecidedApril 24, 2025
Docket2:23-cv-00056
StatusUnknown

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

Bluebook
Parkins v. Barden, (E.D. Ark. 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT EASTERN DISTRICT OF ARKANSAS DELTA DIVISION MICHAEL JUSTIN PARKINS PLAINTIFF ADC #168018 V. Case No. 2:23-CV-00056-BSM-BBM ROOSEVELT G. BARDEN, Captain, EARU, ADC DEFENDANT RECOMMENDED DISPOSITION

The following Recommended Disposition (“Recommendation”) has been sent to United States District Judge Brian S. Miller (“Judge Miller”). You may file written objections to all or part of this Recommendation. If you do so, those objections must: (1) specifically explain the factual and/or legal basis for your objection; and (2) be received by the Clerk of this Court within fourteen (14) days of the date of this Recommendation. If you do not file objections, Judge Miller may adopt this Recommendation without independently reviewing all of the evidence in the record. By not objecting, you may waive the right to appeal questions of fact. I. INTRODUCTION On March 13, 2023, Plaintiff Michael Justin Parkins (“Parkins”), a prisoner incarcerated in the East Arkansas Regional Unit (“EARU”) of the Arkansas Division of Correction (“ADC”), filed a pro se Complaint pursuant to 42 U.S.C. § 1983, alleging that his constitutional rights were violated. (Doc. 2). Parkins also filed a Supplement, “Additional Supporting Evidence,” and a Notice. (Docs. 3, 4, 6). On November 1, 2023,

Judge Miller accepted this Court’s recommendation that Parkins be allowed to proceed with his conditions-of-confinement claims against Captain Roosevelt Barden (“Barden”) and Sergeant J.J. Sykes (“Sykes”), in their individual capacities only, for conduct that occurred in June 2020. (Docs. 8, 9). Specifically, Parkins’s claims are based on allegations

that Barden and Sykes placed him in a small cage for two days without clothes or adequate bathroom breaks. (Doc. 2 at 2–3). At the screening stage, all other claims and Defendants were dismissed. (Docs. 8, 9). After Barden’s Motion to Dismiss was denied, (see Docs. 15–16, 22, 31, 34), Barden filed an Answer on May 21, 2024, (Doc. 37). Parkins’s claims against Sykes were

dismissed without prejudice on September 23, 2024, due to lack of service. (Docs. 52, 54). Thereafter, on October 7, 2024, Barden filed a Motion for Summary Judgment, a Brief in Support, and a Statement of Facts, arguing that Parkins failed to exhaust his administrative remedies. (Docs. 55–57). On October 28, 2024, Parkins filed a document titled, “Response Summary

Judgement Declaration in Opposition to Defendants Motion for Summary Judgement.”1 (Doc. 59 at 1) (errors in original). For ease of analysis, throughout this Recommendation, the Court refers to this document as “Parkins’s Response.” Barden filed a Reply on November 4, 2024. (Doc. 60). Thus, the issues are properly joined and ready for consideration. For the following reasons, the Court recommends that Barden’s Motion for

Summary Judgment, (Doc. 55), be granted.

1 The Court corrects any capitalization errors in Parkins’s writing internally and without brackets. II. DISCUSSION A. Exhaustion Requirement The Prison Litigation Reform Act (“PLRA”) requires prisoners to exhaust all available administrative remedies prior to filing a § 1983 action. 42 U.S.C. § 1997e(a);

Woodford v. Ngo, 548 U.S. 81, 85 (2006); Muhammad v. Mayfield, 933 F.3d 993, 1000 (8th Cir. 2019). In order to do so, prisoners must fully and properly exhaust their available administrative remedies as to each claim that is later raised in a § 1983 action and complete the exhaustion process before initiating the § 1983 action. Jones v. Bock, 549 U.S. 199, 211, 219–20, 223–24 (2007); Woodford, 548 U.S. at 93–95; Burns v. Eaton, 752 F.3d 1136,

1141–42 (8th Cir. 2014); Johnson v. Jones, 340 F.3d 624, 626–28 (8th Cir. 2003) (“Under the plain language of section 1997e(a), an inmate must exhaust administrative remedies before filing suit in federal court…If exhaustion was not completed at the time of filing, dismissal is mandatory.”) (emphasis in original). Importantly, “it is the prison’s requirements, and not the PLRA, that define the boundaries of proper exhaustion.” Jones,

549 U.S. at 218; see also Woodford, 548 U.S. at 90. Thus, to satisfy the PLRA, a prisoner must comply with the exhaustion requirements of the incarcerating facility before he can properly bring a claim in a § 1983 action. The PLRA, however, “requires exhaustion of only ‘such administrative remedies as are available.’” Townsend v. Murphy, 898 F.3d 780, 783 (8th Cir. 2018) (quoting 42 U.S.C.

§ 1997e(a)). And a court must determine whether administrative remedies were unavailable before determining that failure to exhaust remedies bars a prisoner’s lawsuit. Smith v. Andrews, 75 F.4th 805, 808–09 (8th Cir. 2023). For a remedy to be available, it must be capable of use to obtain some relief. Ross v. Blake, 578 U.S. 632, 642 (2016) (cleaned up). An administrative remedy is not capable of use where: (1) it operates as a simple dead end—with officers unable or consistently unwilling to provide any relief to aggrieved

inmates; (2) some mechanism exists to provide relief, but no ordinary prisoner can discern or navigate it; and (3) prison administrators thwart inmates from taking advantage of a grievance process through machination, misrepresentation, or intimidation. Id. at 643–44. B. ADC Administrative Directive 19-34 The ADC provides a three-step grievance procedure for prisoners to exhaust their

administrative remedies, Administrative Directive 19-34 (“AD 19-34”). (Doc. 57-1). First, the prisoner must file a “Step One” informal resolution within fifteen days of each incident. AD 19-34 at § IV(E). The prisoner may only raise one issue in the Step One informal resolution and must be “specific as to the substance of the issue or complaint to include the date, place, personnel involved or witnesses.” AD 19-34 at § IV(D)(2), (E). The prisoner

should receive a response within three working days; but, if no response is received, the prisoner may proceed directly to Step Two. Id. at § IV(E)(11). At “Step Two,” the prisoner submits a formal unit-level grievance. Id. at § IV(F). The Step Two grievance must contain “an explanation [of] why the inmate considers the informal resolution unsuccessful.” Id. at § IV(F)(1). Notably, the prisoner may not raise new issues in his formal grievance, and issues not raised in Step One will not be considered

at Step Two. Id. at § IV(F)(2). If the prisoner does not receive a response to their Step Two grievance within five working days, the prisoner may move to Step Three. Id. at § IV(F)(4), (9). The prisoner must file a “Step Three” appeal to the appropriate ADC Chief Deputy/Deputy/Assistant Director within five working days of the Step Two decision. Id. at § IV(G). At Step Three, the prisoner must “state a reason for the appeal.” Id. at

§ IV(G)(2). The grievance procedure cautions prisoners that they should “not list additional issues, requests, or names which were not part of the original grievance, as those issues will not be addressed.” Id. C. Barden’s Motion for Summary Judgment2 In support of his Motion for Summary Judgment, Barden attaches the Declaration

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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)
Jones v. Bock
549 U.S. 199 (Supreme Court, 2007)
Torgerson v. City of Rochester
643 F.3d 1031 (Eighth Circuit, 2011)
Roy Burns v. Edward Eaton
752 F.3d 1136 (Eighth Circuit, 2014)
Ross v. Blake
578 U.S. 632 (Supreme Court, 2016)
Jacob Townsend v. Terry Murphy
898 F.3d 780 (Eighth Circuit, 2018)
Abdulhakim Muhammad v. Joshua Mayfield
933 F.3d 993 (Eighth Circuit, 2019)
John Smith v. Jeremy Andrews
75 F.4th 805 (Eighth Circuit, 2023)

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Parkins v. Barden, Counsel Stack Legal Research, https://law.counselstack.com/opinion/parkins-v-barden-ared-2025.