Martin v. Knight

Summary

The document contains Findings and Recommendations from the United States District Court for the Eastern District of California in a prisoner civil-rights action under 42 U.S.C. § 1983. The magistrate judge recommends denying Defendant Knight’s motion for summary judgment based on failure to exhaust administrative remedies, finding that Defendant did not establish the absence of exhaustion, particularly because a potentially relevant health-care grievance was not investigated. The parties were given fourteen days to file objections.

Holdings

1. A defendant seeking summary judgment for failure to exhaust must prove both that an administrative remedy was available and that the prisoner did not exhaust it; the ultimate burden of proof remains with the defendant.
2. Summary judgment must be denied when the evidence, viewed in the light most favorable to the prisoner, does not establish failure to exhaust and leaves material exhaustion facts unresolved.
3. Under Ninth Circuit precedent, PLRA exhaustion is assessed based on the filing date of the operative complaint, and a prisoner may supplement a complaint with facts concerning exhaustion.

Questions Presented

1. Whether Defendant Knight proved that Martin failed to exhaust available administrative remedies before filing the operative complaint.
2. Whether summary judgment was appropriate when the evidence did not establish what happened to, or whether Martin exhausted, the potentially relevant health-care appeal.

Disposition

other