Andre Lee Hilliard v. Clark, et al.

Summary

The United States District Court for the Northern District of Illinois granted Defendant Elizabeth English-Lindsey’s motion for summary judgment in a 42 U.S.C. § 1983 action alleging deliberate indifference to medical needs. The court held that the plaintiff failed to exhaust administrative remedies because his grievances neither named English-Lindsey nor provided sufficient identifying information to alert prison officials that she was accused of wrongdoing.

Holdings

1. Prison officials' response to the merits of a grievance does not eliminate the failure-to-exhaust defense where the grievance did not identify the defendant or provide sufficient information for officials to determine that the defendant was accused of wrongdoing.
2. A prisoner need not identify a defendant by name in a grievance, but must provide identifying information sufficient for prison officials to determine that the defendant was accused of wrongdoing.
3. Hilliard failed to exhaust available administrative remedies concerning his allegations against English-Lindsey.

Questions Presented

1. Whether English-Lindsey was entitled to summary judgment because Hilliard failed to exhaust administrative remedies concerning his allegations against her.
2. Whether prison officials' merits responses to Hilliard's grievance precluded English-Lindsey from asserting failure to exhaust.
3. Whether a prisoner must name a defendant in a grievance, or provide identifying information sufficient to alert prison officials that the defendant is accused of wrongdoing.

Disposition

other