Chappel Craigen v. Anthony Wills and Samuel Sterrett

Summary

The United States District Court for the Southern District of Illinois grants Defendants’ motion for summary judgment in an inmate’s 42 U.S.C. § 1983 action concerning access to Islamic religious services. The court holds that Plaintiff failed to exhaust available administrative remedies under the Prison Litigation Reform Act because he did not appeal his grievance to the Administrative Review Board, and dismisses the claims without prejudice.

Holdings

1. Craigen failed to exhaust his administrative remedies because he did not appeal his religious-exercise grievance to the Administrative Review Board, the final level of review required by the Illinois grievance process.
2. A prisoner's belief that pursuing an administrative appeal would be futile does not excuse failure to complete the available grievance process.
3. No evidentiary hearing was required because there was no genuine dispute of material fact concerning exhaustion and the issue could be resolved as a matter of law.

Questions Presented

1. Whether Defendants were entitled to summary judgment because Craigen failed to fully exhaust available administrative remedies before filing his section 1983 and related constitutional and statutory claims.
2. Whether Craigen's belief that an appeal to the Administrative Review Board would be futile excused his failure to complete the grievance process.
3. Whether the undisputed exhaustion facts required an evidentiary hearing.

Disposition

dismissed