Sisson v. Lockhart

CourtDistrict Court, E.D. Arkansas
DecidedOctober 6, 2025
Docket3:25-cv-00020
StatusUnknown

This text of Sisson v. Lockhart (Sisson v. Lockhart) 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
Sisson v. Lockhart, (E.D. Ark. 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT EASTERN DISTRICT OF ARKANSAS NORTHERN DIVISION

PEYTON SISSON PLAINTIFF ADC #172211

v. No: 3:25-cv-00020-DPM-PSH

MEGAN LOCKHART DEFENDANT

PROPOSED FINDINGS AND RECOMMENDATION

INSTRUCTIONS

The following Recommendation has been sent to United States District Judge D.P. Marshall Jr. 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 this Recommendation. By not objecting, you may waive the right to appeal questions of fact. DISPOSITION Plaintiff Peyton Sisson, an inmate at the Grimes Unit of the Arkansas Division of Correction, filed a pro se complaint pursuant to 42 U.S.C. § 1983 on February 24, 2025 (Doc. No. 2). The Court screened Sisson’s amended complaint (Doc. No. 4), and concluded that he may proceed with his claims against defendant Megan Lockhart. See Doc. No. 5. His claims against defendants Aundrea Culclager, Ashley Jackson, and Crystal Reed were dismissed for failure to state a claim upon which relief may be granted. See Doc. No. 21.

Before the Court is a motion for summary judgment, brief in support, and statement of undisputed facts filed by Lockhart (Doc. Nos. 16-18). Lockhart seeks judgment as a matter of law on grounds that Sisson did not exhaust his administrative

remedies as to his claims against her before he filed this action. Sisson filed a response to Lockhart’s motion (Doc. No. 19), and Lockhart filed a reply (Doc. No. 20). For the reasons described herein, the undersigned recommends that Lockhart’s motion for summary judgment be GRANTED.

II. Legal Standard Under Rule 56 of the Federal Rules of Civil Procedure, summary judgment is proper if “the movant shows that there is no genuine dispute as to any material fact

and that the moving party is entitled to a judgment as a matter of law.” Fed. R. Civ. P. 56(a); Celotex v. Catrett, 477 U.S. 317, 321 (1986). When ruling on a motion for summary judgment, the court must view the evidence in a light most favorable to the nonmoving party. Naucke v. City of Park Hills, 284 F.3d 923, 927 (8th Cir.

2002). The nonmoving party may not rely on allegations or denials, but instead must demonstrate the existence of specific facts that create a genuine issue for trial. Mann v. Yarnell, 497 F.3d 822, 825 (8th Cir. 2007). The nonmoving party’s allegations

must be supported by sufficient probative evidence that would permit a finding in his favor on more than mere speculation, conjecture, or fantasy. Id. (citations omitted). An assertion that a fact cannot be disputed or is genuinely disputed must

be supported by materials in the record such as “depositions, documents, electronically stored information, affidavits or declarations, stipulations (including those made for purposes of the motion only), admissions, interrogatory answers, or

other materials . . .”. Fed. R. Civ. P. 56(c)(1)(A). A party may also show that a fact is disputed or undisputed by “showing that the materials cited do not establish the absence or presence of a genuine dispute, or that an adverse party cannot produce admissible evidence to support the fact.” Fed. R. Civ. P. 56(c)(1)(B). A dispute is

genuine if the evidence is such that it could cause a reasonable jury to return a verdict for either party; a fact is material if its resolution affects the outcome of the case. Othman v. City of Country Club Hills, 671 F.3d 672, 675 (8th Cir. 2012). Disputes

that are not genuine or that are about facts that are not material will not preclude summary judgment. Sitzes v. City of West Memphis, Ark., 606 F.3d 461, 465 (8th Cir. 2010). III. Analysis

Lockhart argues that Sisson’s claims against her should be dismissed because he failed to exhaust his administrative remedies before he filed this lawsuit. In support of her motion, Lockhart submitted a declaration by Brandy Johnson, the

ADC’s Medical Grievance Coordinator (Doc. No. 18-1 at 1-2); a copy of grievance GR-24-1347 (id. at 3-5); and a copy of the ADC’s grievance procedure, Administrative Directive 19-34 (Doc. No. 18-2). Sisson did not submit any

additional grievances with his response. See Doc. No. 19. A. Exhaustion of Administrative Remedies The Prison Litigation Reform Act (PLRA) requires an inmate to exhaust

prison grievance procedures before filing suit in federal court. See 42 U.S.C. §1997e(a); Jones v. Bock, 549 U.S. 199, 202 (2007); Burns v. Eaton, 752 F.3d 1136, 1141 (8th Cir. 2014). Exhaustion under the PLRA is mandatory. Jones v. Bock, 549 U.S. at 211; Hammett v. Cofield, 681 F.3d 945, 949 (8th Cir. 2012). “[T]he PLRA’s

exhaustion requirement applies to all inmate suits about prison life whether they involve general circumstances or particular episodes, and whether they allege excessive force or some other wrong.” Porter v. Nussle, 534 U.S. 516, 532 (2002).

The PLRA does not prescribe the manner in which exhaustion occurs. See Jones v. Bock, 549 U.S. at 218. It merely requires compliance with prison grievance procedures to properly exhaust. See id. Thus, the question as to whether an inmate has properly exhausted administrative remedies will depend on the specifics of that

particular prison’s grievance policy. See id. Pursuant to the ADC’s grievance policy, Administrative Directive 19-34, inmates are provided Unit Level Grievance Forms as part of the Inmate Grievance

Procedure. See Doc. No. 18-2 at 5. To resolve a problem, an inmate must first seek informal resolution by submitting a Step One Unit Level Grievance Form within 15 days after the occurrence of the incident. Id. at 1-2, 7. Inmates are to “specifically

name each individual involved” so that the ADC may complete a proper investigation and response. Id. at 5. The policy provides that only one grievance form

can be submitted per grievance and only one problem/issue should be stated in the grievance, not multiple problems/issues. An inmate must use a separate form for each issue. Only one issue will be addressed. Additional problems/issues contained in the grievance will not be considered as exhausted.

Id. An inmate must be “specific as to the substance of the issue or complaint to include the date, place, personnel involved or witnesses, and how the policy or incident affected the inmate submitting the form.” Id. at 7.

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Related

Porter v. Nussle
534 U.S. 516 (Supreme Court, 2002)
Woodford v. Ngo
548 U.S. 81 (Supreme Court, 2006)
Jones v. Bock
549 U.S. 199 (Supreme Court, 2007)
Sitzes v. City of West Memphis Arkansas
606 F.3d 461 (Eighth Circuit, 2010)
Nidal Othman v. City of Country Club Hills
671 F.3d 672 (Eighth Circuit, 2012)
Mark Hammett v. J. Cofield
681 F.3d 945 (Eighth Circuit, 2012)
Mann v. Yarnell
497 F.3d 822 (Eighth Circuit, 2007)
Roy Burns v. Edward Eaton
752 F.3d 1136 (Eighth Circuit, 2014)

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