Demetrius Flowers v. SGT. Bernard, C/O Garcia, SGT. Delmon, C/O Quatters

Summary

The United States District Court for the Southern District of Illinois ruled on defendants’ motion for summary judgment concerning exhaustion of administrative remedies under the Prison Litigation Reform Act. The court granted the motion as to Garcia, finding the claims against him unexhausted, but denied it as to Dillman and Quertermous, holding that grievance K19-0424-0797 sufficiently exhausted claims concerning cleaning supplies and medical attention. The court allowed the action to proceed against Bernard, Dillman, and Quertermous and dismissed the claim against Garcia without prejudice.

Holdings

1. Plaintiff failed to exhaust Claim 4 against Garcia because grievance K19-0424-0797 mentioned Garcia only as a person present during an incident and did not substantively connect him to the allegations asserted in the amended complaint.
2. Grievance K19-0424-0797 was sufficient to exhaust Claim 4 against Dillman and Quertermous concerning the denial of cleaning supplies and medical attention after the gallery unrest.
3. Summary judgment was granted in part as to Garcia and denied in part as to Dillman and Quertermous.

Questions Presented

1. Whether Plaintiff exhausted his administrative remedies for his conditions-of-confinement claim against Garcia.
2. Whether grievance K19-0424-0797 sufficiently exhausted Plaintiff's claim against Dillman and Quertermous even though it did not name or describe them individually.
3. Whether Defendants were entitled to summary judgment on the PLRA exhaustion defense.

Disposition

other