Boyd v. Pfister, 1:18-cv-03275

Plaintiff Dorian Boyd, while incarcerated at Stateville in Oct–Nov 2016, alleged a cockroach crawled into his left ear, causing pain and diminished hearing; he sought medical care and repeatedly complained to staff.
Boyd submitted informal complaints and two formal grievances: a November 3 grievance (complaining of general cockroach infestation and a roach in his nose; did not mention an ear injury or check the medical box) and a December 1 grievance (explicitly describing a roach removed from his ear, ongoing hearing problems, and continued sick‑call visits).
The November grievance was denied as non‑emergency; the December grievance was denied at the facility level on the ground that Boyd was receiving medical care (not on procedural grounds).
Boyd appealed to the Administrative Review Board (ARB), which classified the complaint as medical, noted a roach had been removed from his ear, found the facility had addressed the issue, and denied relief on May 24, 2017.
Defendants moved for summary judgment arguing Boyd failed to exhaust administrative remedies because (1) he did not name responsible staff in his grievances and (2) he did not clearly raise a medical complaint. The court denied summary judgment, concluding Boyd exhausted his administrative remedies.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Boyd exhausted by naming defendants in grievance	Boyd argued the ARB and facility addressed the grievance on the merits so naming was unnecessary	Defendants argued §504.810 requires naming involved persons and failure to do so is non‑exhaustion	Court: Exhaustion satisfied — prison decided grievances on the merits and never invoked procedural defect; failure to name was a harmless technicality (citing Maddox/Conyers principle)
Whether Boyd exhausted a medical claim	Boyd argued December grievance explicitly described ear injury, removal, ongoing hearing loss and sick calls	Defendants argued grievances did not sufficiently raise medical treatment/indifference claims	Court: Exhaustion satisfied — December grievance and ARB categorized it as medical and facility responded that he was receiving care, providing the notice exhaustion requires
Which grievance governs claim specificity (claim‑specific exhaustion)	Boyd relied on December 1 grievance as the one that put prison on notice of ear injury	Defendants pointed to earlier November grievance’s omissions	Court: Only the December grievance needed to be exhausted for these claims; it adequately alerted the prison to the nature of the wrong

Celotex Corp. v. Catrett, 477 U.S. 317 (summary judgment standard)
Anderson v. Liberty Lobby, Inc., 477 U.S. 242 (genuine dispute / jury standard)
Ross v. Blake, 136 S. Ct. 1850 (PLRA exhaustion is mandatory)
Pavey v. Conley, 544 F.3d 739 (procedures for resolving exhaustion disputes)
Jones v. Bock, 549 U.S. 199 (exhaustion and prisoner notice policy)
Woodford v. Ngo, 548 U.S. 81 (exhaustion requires compliance with prison procedures)
Maddox v. Love, 655 F.3d 709 (failure to name defendants not fatal where grievance decided on merits)
Conyers v. Abitz, 416 F.3d 580 (grievance resolved on merits cures procedural defects)
Ford v. Johnson, 362 F.3d 395 (grievance requirement and scope)
Riccardo v. Rausch, 375 F.3d 521 (claim‑specific exhaustion / notice requirement)
Turley v. Rednour, 729 F.3d 645 (purpose of exhaustion is to alert prison and invite correction)
Schillinger v. Kiley, 954 F.3d 990 (content sufficiency judged by whether prison was alerted)