David Velazquez-Diaz v. Rachel Young, Karas Correctional Health (KCH); Dr. Robert Karas, KCH; Kelley Hinely, KCH; Dustin Sanders, KCH; Jordan Provenas, KCH; Jacob Smothers, KCH; John and Jane Doe Employees of KCH; and Sheriff Jay Cantrell, Washington County, Arkansas

Summary

The United States District Court for the Western District of Arkansas overruled the plaintiff’s objection to a magistrate judge’s Report and Recommendation concerning exhaustion of administrative remedies under the Prison Litigation Reform Act. The court held that the detention center’s grievance policy required inmates to identify the individuals involved, and the plaintiff’s grievances did not name Sheriff Jay Cantrell or jail officers in connection with the alleged failure to train or supervise medical personnel. The court adopted the Report and Recommendation, granted Cantrell’s motion for summary judgment, and dismissed the claims against him without prejudice.

Holdings

1. When a detention center's grievance policy requires an inmate to name each individual involved in the complained-of incident, that requirement controls for purposes of exhaustion under the Prison Litigation Reform Act.
2. General grievances about the quality of medical care or disagreement with a treatment decision do not exhaust claims against a jail administrator for failing to train or supervise medical personnel when the administrator is not identified in the grievances.

Questions Presented

1. Whether the plaintiff exhausted administrative remedies as to his failure-to-train and failure-to-supervise claims against Sheriff Cantrell when the jail grievance policy required inmates to identify by name the staff members involved and the plaintiff did not name Cantrell or any jailer in his grievances.
2. Whether summary judgment and dismissal without prejudice were proper for failure to exhaust administrative remedies under the Prison Litigation Reform Act.

Disposition

dismissed