Jamerson v. Wilkinson

Summary

The United States District Court for the Western District of Michigan adopted a magistrate judge’s report and recommendation and granted the remaining defendants’ motion for summary judgment. The court concluded that Plaintiff John Jamerson failed to exhaust claims concerning an alleged fall from an upstairs cell because his grievance identified an incident date after he had been transferred to a ground-floor housing unit, and he did not address the evidentiary deficiencies identified in the report.

Holdings

1. Only specific objections to a magistrate judge's report and recommendation are entitled to de novo review; objections that do not address the relevant grounds for the recommendation do not require further de novo consideration.
2. Defendants were entitled to summary judgment because Jamerson's grievance identified February 12, 2021 as the incident date, but the evidence showed that he had been transferred to ground-floor Housing Unit 3 on February 1, 2021; the grievance therefore did not exhaust a claim arising from his earlier Housing Unit 6 assignment.

Questions Presented

1. Whether Jamerson's objections to the magistrate judge's report and recommendation were sufficiently specific to warrant de novo review.
2. Whether defendants were entitled to summary judgment because the grievance used to exhaust Jamerson's claim identified an incident date on which he was housed in a ground-floor unit and therefore did not exhaust a claim arising from his earlier Housing Unit 6 assignment.

Disposition

affirmed