Edward John Loren v. Suzanne Groff, Brandi Avery, and Michael Travis

Summary

The United States District Court for the Western District of Michigan grants defendant Suzanne Groff’s motion for summary judgment in a prisoner civil-rights action under 42 U.S.C. § 1983. The court holds that the plaintiff failed to properly exhaust available administrative remedies because his grievance identified only “Healthcare” and did not name or sufficiently identify Groff or the claims asserted against her. Groff is dismissed with prejudice.

Holdings

1. A prisoner bringing a prison-conditions action under 42 U.S.C. § 1983 must exhaust available administrative remedies in accordance with the applicable prison grievance procedures before filing suit.
2. A grievance identifying "Healthcare" generally, without naming Groff or sufficiently identifying her role and conduct, did not properly exhaust Loren's claims against Groff.
3. Groff was entitled to summary judgment because Loren failed to properly exhaust administrative remedies as to his claims against her.

Questions Presented

1. Whether Loren properly exhausted available administrative remedies against Groff under the PLRA and the MDOC grievance procedures.
2. Whether Loren's grievance identifying "Healthcare" generally was sufficient to exhaust claims against the unnamed and unidentified medical provider Groff.
3. Whether Groff was entitled to summary judgment on the exhaustion defense.

Disposition

dismissed