Mujaahid F. Harris v. O. Valladolid, et al.

Summary

The United States District Court for the Eastern District of California recommends denying the correctional officer defendants’ motion for summary judgment based on failure to exhaust administrative remedies. The court concludes that the plaintiff’s grievance sufficiently alerted prison officials to the nature of his excessive-force and failure-to-protect claims, even though it did not identify every defendant by name. The findings and recommendations were issued under 28 U.S.C. § 636(b)(1), with objections due within thirty days.

Holdings

1. A grievance need not name every staff member involved or provide personal notice to each official who may later be sued; it is sufficient if it alerts prison officials to the nature of the wrong and the problem for which redress is sought.
2. Defendants were not entitled to summary judgment on exhaustion because the undisputedly exhausted grievance sufficiently alerted prison officials to the conduct underlying Plaintiff's claims against the correctional officer defendants.

Questions Presented

1. Whether grievance no. 307260 sufficiently exhausted Plaintiff's excessive-force and failure-to-protect claims against correctional officers who were not individually named in the grievance.
2. Whether Defendants Ramirez, Forbes, Patrick, Butler, and Osmer were entitled to summary judgment based on failure to exhaust administrative remedies under the PLRA.

Disposition

other