Mufti Abdul El-Malik-Bey Ali v. David Liebel et al.

Summary

The court denied Mufti Abdul El-Malik-Bey Ali’s motion under Federal Rule of Civil Procedure 59(e) to reconsider summary judgment for the defendants. It held that the Supreme Court’s decision in Perttu v. Richards did not require a jury trial because exhaustion was not intertwined with the merits of Ali’s religious-rights claims. The court also concluded that Ali had not shown a manifest error of law or fact, because he failed to follow the Indiana Department of Correction’s grievance and appeal procedures before filing suit.

Holdings

1. Perttu did not warrant reconsideration because Ali's exhaustion issue was not intertwined with the merits of a claim requiring a jury trial; resolving exhaustion did not require deciding whether prison officials obstructed his access to the grievance system.
2. Reconsideration under Rule 59(e) is warranted only upon newly discovered evidence or a manifest error of law or fact and cannot be used to present arguments that were or could have been presented before judgment.
3. Ali failed to properly exhaust the administrative remedies available under the prison's grievance policy before filing suit.
4. The grievance process was not rendered unavailable merely because prison officials allegedly failed to respond, because the grievance policy provided specific follow-up and appeal procedures that Ali did not use.

Questions Presented

1. Whether Ali was entitled to Rule 59(e) relief based on Perttu v. Richards and a claimed right to a jury trial on the availability or exhaustion of administrative remedies.
2. Whether the prior summary judgment rested on a manifest error of law or fact concerning the availability of the prison grievance process.
3. Whether Ali properly exhausted the administrative remedies required by the Indiana Department of Correction grievance policy before filing suit.

Disposition

other