Boardman v. Rehman, 2:24-cv-10949

Robert Alan Boardman, an inmate at the Michigan Department of Corrections, filed a pro se civil rights complaint under 42 U.S.C. § 1983 alleging deliberate indifference to a serious medical need.
Boardman claims that after swallowing an ink pen, Shafiq Rehman, N.P., refused proper medical care and made dismissive remarks, resulting in Boardman being hospitalized for nine days and undergoing two surgeries.
Rehman moved for summary judgment solely on the ground that Boardman failed to exhaust his administrative remedies as required by the Prison Litigation Reform Act (PLRA).
MDOC's grievance policy requires inmates to name all individuals involved in their Step I grievance, but Boardman did not name Rehman specifically at Step I.
The prison reviewed Boardman’s grievance and addressed it on its merits at all three steps, specifically discussing the medical care provided by Rehman.
The Court’s recommendation addresses whether this procedural defect precludes Boardman’s lawsuit under the PLRA's exhaustion requirement.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Exhaustion of administrative remedies under PLRA	Exhaustion occurred because prison addressed grievance on merits despite defect	Failure to name Rehman at Step I means exhaustion was deficient	Procedural defect waived; grievance decided on merits, not barred
Adequacy of grievance notice to defendant	Prison was put on notice of Rehman’s conduct due to contextual details provided	Lack of specific name meant no fair opportunity to correct	Prison recognized and addressed Rehman’s conduct; notice sufficient
Waiver of procedural default by prison officials	Officials waived exhaustion procedural requirements by deciding merits	Strict compliance required with grievance policy	Waiver applies if prison ignores defect and decides merits
Purpose of PLRA exhaustion requirement	Ensures officials get fair chance to address issue; met here	Undermined by failing to follow name requirement	Purpose fulfilled; exhaustion requirement satisfied

Woodford v. Ngo, 548 U.S. 81 (proper exhaustion requires compliance with deadlines and critical procedural rules under PLRA)
Jones v. Bock, 549 U.S. 199 (defendant bears burden of proving failure to exhaust is an affirmative defense)
Anderson v. Liberty Lobby, Inc., 477 U.S. 242 (summary judgment standard for determining genuine issues of material fact)
Celotex Corp. v. Catrett, 477 U.S. 317 (movant’s initial burden in summary judgment)
Reed-Bey v. Pramstaller, 603 F.3d 322 (waiver of procedural defects in exhaustion if grievance is decided on merits)
Mattox v. Edelman, 851 F.3d 583 (waiver of requirement to name all individuals if grievance decided on merits by prison officials)