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Hamilton v. Knight

United States District Court, S.D. Indiana, Indianapolis Division

March 1, 2019

JAMES HAMILTON, Plaintiff,
v.
STANLEY KNIGHT, CLINTON FELDKAMP, TY ROBBINS, MORGAN FEENEY, Defendants.

          ENTRY GRANTING MOTION FOR SUMMARY JUDGMENT, DENYING MOTION TO APPOINT COUNSEL AND MOTION FOR SANCTIONS, RELINQUISHING SUPPLEMENTAL JURISDICTION OVER STATE LAW CLAIMS, AND DIRECTING ENTRY OF FINAL JUDGMENT

          TANYA WALTON PRATT, JUDGE

         Plaintiff James Hamilton is a prisoner currently incarcerated at New Castle Correctional Facility. Defendants Stanley Knight, Clinton Feldkamp, Ty Robbins, and Morgan Feeney were staff members at Plainfield Correctional Facility (PCF) when Mr. Hamilton was previously incarcerated there. In this lawsuit, Mr. Hamilton alleges that the defendants failed to protect him from a known threat of violence at PCF in 2017 in a manner that violated his Eighth Amendment rights and amounted to negligence under Indiana law.

         The defendants have moved for summary judgment on the Eighth Amendment claims, arguing that Mr. Hamilton failed to exhaust his available administrative remedies as required by the Prison Litigation Reform Act (PLRA), 42 U.S.C. § 1997e(a), before filing this lawsuit. Believing the Eighth Amendment claims to be barred by the PLRA, the defendants ask the Court to relinquish its supplemental jurisdiction over the negligence claims.

         For the reasons set forth below, the Court grants the defendants' motion for summary judgment. The Court also denies Mr. Hamilton's pending motion to appoint counsel and motion for sanctions, relinquishes its supplemental jurisdiction over Mr. Hamilton's state-law claims, and directs the clerk to enter final judgment in the defendants' favor.

         I. Motion for Summary Judgment

         Summary judgment should be granted “if the movant shows that there is no genuine dispute as to any material fact and the movant is entitled to judgment as a matter of law.” Fed.R.Civ.P. 56(a). “Material facts are those that might affect the outcome of the suit under applicable substantive law.” Dawson v. Brown, 803 F.3d 829, 833 (7th Cir. 2015) (internal quotation omitted). “A genuine dispute as to any material fact exists ‘if the evidence is such that a reasonable jury could return a verdict for the nonmoving party.'” Daugherty v. Page, 906 F.3d 606, 609-10 (7th Cir. 2018) (quoting Anderson v. Liberty Lobby, Inc., 477 U.S. 242, 248 (1986)). The Court views the facts in the light most favorable to the non-moving party, and all reasonable inferences are drawn in the non-movant's favor. See Barbera v. Pearson Education, Inc., 906 F.3d 621, 628 (7th Cir. 2018).

         A. Exhaustion of Administrative Remedies

         The substantive law applicable to the motion for summary judgment is the PLRA, which requires that a prisoner exhaust his available administrative remedies before bringing a suit concerning prison conditions. 42 U.S.C. § 1997e(a); see Porter v. Nussle, 534 U.S. 516, 524-25 (2002). “[T]he PLRA's exhaustion requirement applies to all inmate suits about prison life, whether they involve general circumstances or particular episodes, and whether they allege excessive force or some other wrong.” Id. at 532 (citation omitted).

         “Proper exhaustion demands compliance with an agency's deadlines and other critical procedural rules because no adjudicative system can function effectively without imposing some orderly structure on the course of its proceedings.” Woodford v. Ngo, 548 U.S. 81, 90-91 (2006) (footnote omitted); see also Dole v. Chandler, 438 F.3d 804, 809 (7th Cir. 2006) (“‘To exhaust remedies, a prisoner must file complaints and appeals in the place, and at the time, the prison's administrative rules require.'”) (quoting Pozo v. McCaughtry, 286 F.3d 1022, 1025 (7th Cir. 2002)). “State law establishes the administrative remedies that a state prisoner must exhaust for purposes of the PLRA.” Lanaghan v. Koch, 902 F.3d 683, 687 (7th Cir. 2018). It is well-settled that “there is no ‘futility' exception to a prisoner's duty to exhaust, ” even when the administrative remedies offered by the prison do not include damages. Fletcher v. Menard Corr. Ctr., 623 F.3d 1171, 1173-74 (7th Cir. 2010) (citing Booth v. Churner, 532 U.S. 731 (2001)).

         B. The Grievance Process

         The Indiana Department of Correction (IDOC) Offender Grievance Process (OGP) provides inmates an avenue for resolving complaints regarding the conditions of their confinement. There is no dispute that the OGP was available to Mr. Hamilton at all times relevant to this action. The version of the OGP in effect at that time appears in the record at dkt. 44-1, pp. 8-32.

         The OGP consists of the following three steps:

(i) An informal attempt to solve a problem or address a concern, which can be followed by;
(ii) Submission of a written form outlining the problem or concern and other supporting information, and the response to that submission, which can be followed by;
(iii) A written appeal of the response to a higher authority and the response to that appeal. The Department does not require an offender who is satisfied with the result at any ...

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