Walter R. Sexton v. Watkins, et al.

Sexton · United States District Court for the Eastern District of Arkansas, Central Division · February 11, 2026 · No. 4:25CV00526-LPR-JTK

Summary

This document is a United States magistrate judge’s Proposed Findings and Recommendations in a prisoner civil-rights action concerning allegedly inadequate sleeping mats and discriminatory treatment at the Faulkner County Detention Center. The magistrate judge recommends granting defendants’ summary-judgment motion because the plaintiff failed to exhaust available administrative remedies, dismissing the claims and complaint without prejudice, and certifying that an appeal would not be taken in good faith.

Holdings

  1. The Prison Litigation Reform Act requires a prisoner to exhaust available administrative remedies before bringing an action concerning prison conditions under § 1983 or other federal law.
  2. Plaintiff failed to exhaust available administrative remedies because he filed no grievance related to the claims in this lawsuit before initiating the action.
  3. Summary judgment was appropriate because Plaintiff did not controvert Defendants' asserted material facts and the undisputed record established nonexhaustion.
  4. The PLRA itself does not require that every defendant be specifically named in an administrative grievance; the applicable prison grievance requirements define the boundaries of proper exhaustion.

Questions Presented

  1. Whether Defendants were entitled to summary judgment because Plaintiff failed to exhaust available administrative remedies before filing his § 1983 action.
  2. Whether Plaintiff's failure to respond permitted the court to deem Defendants' asserted material facts admitted under the local rules and Federal Rule of Civil Procedure 56.
  3. Whether Plaintiff's complaint should be dismissed without prejudice for failure to exhaust.

Disposition

dismissed

Cases Cited (10)

  • Dulany v. Carnahan, 132 F.3d 1234, 1237 (8th Cir. 1997)(followed)
  • Webb v. Lawrence County, 144 F.3d 1131, 1134-35 (8th Cir. 1998)(followed)
  • Celotex Corp. v. Catrett, 477 U.S. 317, 323 (1986)(followed)
  • Booth v. Churner, 532 U.S. 731, 741 (2001)(followed)
  • Chelette v. Harris, 229 F.3d 684, 688 (8th Cir. 2000)(followed)
  • Castano v. Nebraska Dep't of Corrections, 201 F.3d 1023, 1025 (8th Cir. 2000)(followed)
  • Johnson v. Jones, 340 F.3d 624, 627 (8th Cir. 2003)(followed)
  • Jones v. Bock, 549 U.S. 199, 218 (2007)(followed)
  • Wilson v. Miller, 821 F.3d 963, 970 (8th Cir. 2016)(followed)
  • Bolderson v. City of Wentzville, Missouri, 840 F.3d 982, 986-87 (8th Cir. 2016)(followed)

Cited In (0)

No citing cases on record yet.

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