Cornelius Williams, Jr. v. J. Pryor, et al.

Summary

The United States District Court for the Middle District of Alabama dismissed without prejudice Cornelius Williams, Jr.’s 42 U.S.C. § 1983 action against Alabama Department of Corrections officers. The court held that Williams failed to properly exhaust available administrative remedies under the Prison Litigation Reform Act and the ADOC’s Administrative Regulation 406 grievance process. The court expressed no opinion on the merits of his excessive-force and related claims.

Holdings

1. The action had to be dismissed without prejudice because Williams failed to properly exhaust the available administrative remedies established by ADOC Administrative Regulation 406 before filing suit.
2. Contacting the ADOC's Internal Investigations division, now the Law Enforcement Services Division, did not satisfy the ADOC's grievance policy and did not establish that the grievance process was unavailable.
3. Even assuming that Williams's statement that he filed a complaint with Mr. R. White created a factual dispute, dismissal remained warranted under Turner's second step because the statement was vague and conclusory and the defendants' evidence showed that no grievance concerning the incident had been filed.

Questions Presented

1. Whether the complaint must be dismissed because Williams failed to exhaust available administrative remedies under the PLRA before filing his § 1983 action.
2. Whether contacting the ADOC's Internal Investigations or Law Enforcement Services Division satisfied the ADOC's grievance procedures or demonstrated that those procedures were unavailable.
3. Whether Williams's vague assertion that he filed a complaint with Mr. R. White created a factual dispute requiring further proceedings under the second step of Turner.

Disposition

dismissed