Wade v. Valenza (INMATE 1)

CourtDistrict Court, M.D. Alabama
DecidedSeptember 21, 2020
Docket1:19-cv-00340
StatusUnknown

This text of Wade v. Valenza (INMATE 1) (Wade v. Valenza (INMATE 1)) is published on Counsel Stack Legal Research, covering District Court, M.D. Alabama primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Wade v. Valenza (INMATE 1), (M.D. Ala. 2020).

Opinion

IN THE DISTRICT COURT OF THE UNITED STATES FOR THE MIDDLE DISTRICT OF ALABAMA SOUTHERN DIVISION

ROBERT WADE, AIS #181328 ) ) Plaintiff, ) ) CASE NO. 1:19-CV-340-ECM-KFP ) (WO) SHERIFF DONALD VALENZA, et al., ) ) Defendants. )

RECOMMENDATION OF THE MAGISTRATE JUDGE I. INTRODUCTION1 Plaintiff, Robert Wade, an indigent inmate, filed this 42 U.S.C. § 1983 action challenging conditions of a previous term of confinement at the Houston County Jail. Doc. 1 at 1–3. Defendants filed a special report and supporting evidentiary materials denying that they acted in violation of Wade’s constitutional rights and arguing that this case should be dismissed because Wade failed to properly exhaust the administrative remedy available to him before filing this action. Doc. 24 at 5–7. Defendants base their exhaustion defense on Wade’s failure to file any grievance regarding the claims presented in this case. Docs. 24-3 at 2–3, 24-4 at 2, 24-5 at 2–3, and 24-6 at 2–3. Defendants further argue that, because Wade did not file a grievance within the time required by the grievance procedure, he “failed to exhaust his administrative remedies and can never exhaust them.” Doc. 24 at 7.

1All cited documents and attendant page numbers are those assigned by the Clerk of Court in the docketing process. The Court specifically ordered Wade to address Defendants’ exhaustion argument and advised that his response should be supported by “affidavits, declarations/statements made under penalty of perjury or other appropriate evidentiary materials[.]” Doc. 25 at 1,

3. In addition, the Court cautioned Wade that, unless “sufficient legal cause” is shown within fifteen (15) days of entry of this order “why such action should not be undertaken, . . . the court may at any time [after expiration of the time for his filing a response] and without further notice to the parties (1) treat the special report and any supporting evidentiary materials as a motion to dismiss or motion for summary judgment, whichever

is proper, and (2) after considering any response as allowed by this order, rule on the motion in accordance with the law.” Doc 25 at 4 (emphasis in original and footnote omitted). The deadline for Wade to respond to the Court’s Order expired over one year ago, and Wade has filed no response. Accordingly, the Court treats Defendants’ special report as a Motion to Dismiss with respect to the exhaustion defense, and this case is now pending on that motion. Bryant

v. Rich, 530 F.3d 1368, 1374-75 (11th Cir. 2008) (internal quotations omitted) (“[A]n exhaustion defense . . . is not ordinarily the proper subject for a summary judgment [motion]; instead, it should be raised in a motion to dismiss, or be treated as such if raised in a motion for summary judgment.”); Trias v. Florida Dept. of Corrections, 587 F. App’x 531, 534 (11th Cir. 2014) (holding that the district court properly construed Defendant’s

motion for summary judgment as a motion to dismiss for failure to exhaust administrative remedies). II. STANDARD OF REVIEW Under 42 U.S.C. § 1997e(a), the Prison Litigation Reform Act (PLRA), a prisoner must exhaust any administrative remedies available to him before filing a suit in federal

court based on alleged violations of his constitutional rights or other federal laws. Specifically, § 1997e(a) directs 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.

Concerning this exhaustion requirement, the Eleventh Circuit has stated: We have recognized that “[t]he plain language of th[is] statute makes exhaustion a precondition to filing an action in federal court.” Higginbottom v. Carter, 223 F.3d 1259, 1261 (11th Cir. 2000) (per curiam) (quoting Freeman v. Francis, 196 F.3d 641, 643–44 (6th Cir. 1999)). This means that “until such administrative remedies as are available are exhausted,” a prisoner is precluded from filing suit in federal court. See id. (affirming dismissal of prisoner’s civil rights suit for failure to satisfy the mandatory exhaustion requirements of the PLRA); Harris v. Garner, 190 F.3d 1279, 1286 (11th Cir. 1999) (“reaffirm[ing] that section 1997e(a) imposes a mandatory requirement on prisoners seeking judicial relief to exhaust their administrative remedies” before filing suit in federal court), modified on other grounds, 216 F.3d 970 (11th Cir. 2000) (en banc); Miller v. Tanner, 196 F.3d 1190, 1193 (11th Cir. 1999) (holding that under the PLRA’s amendments to § 1997e(a), “[a]n inmate incarcerated in a state prison . . . must first comply with the grievance procedures established by the state department of corrections before filing a federal lawsuit under section 1983”); Harper v. Jenkin, 179 F.3d 1311, 1312 (11th Cir. 1999) (per curiam) (affirming dismissal of prisoner’s civil suit for failure to satisfy the mandatory exhaustion requirements of § 1997e(a)); Alexander v. Hawk, 159 F.3d 1321, 1328 (11th Cir. 1998) (affirming dismissal of prisoner’s Bivens action under § 1997e(a) for failure to exhaust administrative remedies prior to filing suit in federal court). Leal v. Georgia Dept. of Corrections, 254 F.3d 1276, 1279 (11th Cir. 2001) (emphasis in original). The law is well-settled that the question of exhaustion is “a threshold matter that

[federal courts must] address before considering the merits of the case. Because exhaustion is mandated by the statute, [a federal court has] no discretion to waive this requirement.” Myles v. Miami-Dade County Correctional and Rehabilitation Dept., 476 F. App’x 364, 366 (11th Cir. 2012) (internal quotations omitted) (citing Chandler v. Crosby, 379 F.3d 1278, 1286 (11th Cir. 2004) and Alexander v. Hawk, 159 F.3d 1321, 1325–26 (11th Cir.

1998)). The Court will therefore “resolve this issue first.” Myles, 476 F. App’x at 366. “When deciding whether a prisoner has exhausted his remedies, the court should first consider the plaintiff’s and the defendants’ versions of the facts, and if they conflict, take the plaintiff’s version of the facts as true. If in that light, the defendant is entitled to have the complaint dismissed for failure to exhaust administrative remedies, it must be dismissed. If the complaint is not subject to dismissal at this step, then the court should

make specific findings in order to resolve the disputed factual issues related to exhaustion.” Myles, 476 F. App’x at 366 (internal quotations omitted) (citing Turner v. Burnside, 541 F.3d 1077, 1082 (11th Cir. 2008)). Consequently, a district court “may resolve disputed factual issues where necessary to the disposition of a motion to dismiss for failure to exhaust [without a hearing]. The judge properly may consider facts outside of the pleadings

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

Related

Alexander v. Hawk
159 F.3d 1321 (Eleventh Circuit, 1998)
Harper v. Jenkin
179 F.3d 1311 (Eleventh Circuit, 1999)
Harris v. Garner
190 F.3d 1279 (Eleventh Circuit, 1999)
Miller v. Tanner
196 F.3d 1190 (Eleventh Circuit, 1999)
Jim E. Chandler v. James Crosby
379 F.3d 1278 (Eleventh Circuit, 2004)
David Johnson v. Tydus Meadows
418 F.3d 1152 (Eleventh Circuit, 2005)
Bryant v. Rich
530 F.3d 1368 (Eleventh Circuit, 2008)
Turner v. Burnside
541 F.3d 1077 (Eleventh Circuit, 2008)
Porter v. Nussle
534 U.S. 516 (Supreme Court, 2002)
Woodford v. Ngo
548 U.S. 81 (Supreme Court, 2006)
Larry Bonner v. City of Prichard, Alabama
661 F.2d 1206 (Eleventh Circuit, 1981)
Murray Stein v. Reynolds Securities, Inc.
667 F.2d 33 (Eleventh Circuit, 1982)
Tanya Marsh v. Johnnie W. Jones, Jr., Warden
53 F.3d 707 (Fifth Circuit, 1995)
Christopher Troy Myles v. Anthony Green
476 F. App'x 364 (Eleventh Circuit, 2012)
Lawrence Rupert Smith v. William Terry
491 F. App'x 81 (Eleventh Circuit, 2012)
Trias v. Florida Department of Corrections
587 F. App'x 531 (Eleventh Circuit, 2014)

Cite This Page — Counsel Stack

Bluebook (online)
Wade v. Valenza (INMATE 1), Counsel Stack Legal Research, https://law.counselstack.com/opinion/wade-v-valenza-inmate-1-almd-2020.