Gary Lentz v. MDOC et al.

Summary

The United States District Court for the Eastern District of Michigan adopts a magistrate judge’s report and recommendation in Gary Lentz’s prisoner civil-rights action. The court overrules Lentz’s objections, holds that his claims were not exhausted through appeals of involuntary-treatment hearing decisions, and concludes that Perttu v. Richards does not require a jury trial where exhaustion is undisputed. Several defendants are dismissed without prejudice for failure to exhaust, Wellpath is dismissed based on bankruptcy discharge, and the case continues against the remaining defendants.

Holdings

1. The court may address untimely objections because the objection deadline is procedural rather than jurisdictional, and the court may excuse compliance in the interests of justice.
2. A Michigan prisoner must exhaust challenges to involuntary-treatment-committee hearings through the ordinary MDOC three-step grievance process; an appeal of the Hearing Committee's decision alone does not exhaust the claims.
3. Perttu v. Richards does not require a jury trial or preclude summary judgment when the exhaustion issue is not intertwined with the merits and there is no genuine dispute of material fact concerning exhaustion.
4. The MDOC defendants' motion for summary judgment was granted in part and denied in part; specified defendants were dismissed without prejudice for failure to exhaust, Wellpath's motion to dismiss was granted based on bankruptcy discharge, and Bailey's motion for summary judgment was granted.

Questions Presented

1. Whether the plaintiff's objections to the magistrate judge's report and recommendation should be considered despite being filed after the fourteen-day deadline.
2. Whether appeals from a Hearing Committee decision concerning involuntary treatment exhaust a Michigan prisoner's claims without proceeding through the ordinary MDOC grievance process.
3. Whether Perttu v. Richards required a jury trial or otherwise precluded summary judgment on PLRA exhaustion under the circumstances presented.
4. Whether the magistrate judge's recommendations to grant or partially grant defendants' motions and dismiss specified defendants should be adopted.

Disposition

other