Timothy Flynn v. Coty Holland

Summary

The United States District Court for the Eastern District of Tennessee granted Defendant Coty Holland’s motion for summary judgment in Timothy Flynn’s 42 U.S.C. § 1983 retaliation action. The court held that Flynn failed to exhaust available Tennessee Department of Correction administrative remedies under the Prison Litigation Reform Act and dismissed the action without prejudice.

Holdings

1. The Prison Litigation Reform Act required Plaintiff to properly exhaust the available TDOC grievance procedures before bringing his § 1983 action, regardless of the type of relief sought or whether the requested relief could be granted through the administrative process.
2. Plaintiff failed to exhaust the available TDOC administrative remedies because he did not file a grievance concerning Defendant's alleged retaliation, and Defendant was therefore entitled to summary judgment.

Questions Presented

1. Whether Defendant was entitled to summary judgment because Plaintiff failed to properly exhaust the available TDOC grievance procedure before filing the § 1983 retaliation action.
2. Whether the undisputed evidence established that the TDOC administrative remedies were available and that Plaintiff did not pursue them.

Disposition

dismissed