Phillip Anglin v. Lisa Draper et al.

Summary

The United States District Court for the Central District of Illinois denied Defendant Zia Samad’s motion for summary judgment based on Plaintiff Phillip Anglin’s alleged failure to exhaust administrative remedies under the Prison Litigation Reform Act. The court held that Samad had not provided evidence showing that Anglin failed to appeal his grievances to the Office of Jail and Detention Standards, and that the jail’s grievance procedures did not require Anglin to identify Samad by name.

Holdings

1. Defendant Samad was not entitled to summary judgment because, as the party asserting exhaustion as an affirmative defense, he failed to provide evidence demonstrating that Plaintiff did not fully exhaust the available grievance and appeal procedures.
2. Plaintiff was not required to identify Defendant Samad explicitly by name because the Jail handbook did not impose that requirement.

Questions Presented

1. Whether Defendant Samad was entitled to summary judgment because Plaintiff failed to exhaust the Jail's administrative grievance and appeal procedures before filing suit.
2. Whether Plaintiff was required by the Jail's grievance procedures to identify Defendant Samad explicitly in his grievances.

Disposition

other