Chandler v. Federal Bureau of Prisons
226 F. Supp. 3d 1
| D.D.C. | 2016Background
- Plaintiff Johnny Ray Chandler, Sr., an inmate at ADX Florence, alleges he experienced chest pains on Feb. 27, 2016 and that on‑duty nurse Cathlin Olguin failed to respond to his requests for medical assistance.
- Chandler brought claims construed as negligence under the Federal Tort Claims Act (FTCA), constitutional claims under 42 U.S.C. § 1983 (prison conditions/medical care), and a breach of contract claim against the BOP seeking $100,000 per defendant and disciplinary relief for Olguin.
- BOP records show Chandler submitted numerous administrative remedy requests between Feb. 27 and Oct. 1, 2016, but none that specifically raised the February 27, 2016 incident; BOP opened two administrative tort investigations and denied both within six months.
- Chandler filed an administrative tort claim on March 10, 2016; the BOP did not have final agency denials for the related claims before Chandler filed suit in Superior Court on March 21, 2016.
- Defendants moved to dismiss or for summary judgment; Chandler did not oppose the motion or seek additional time after being warned. The Court reviewed the merits notwithstanding the lack of opposition.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether FTCA claim is ripe/exhausted | Chandler asserts negligence by a BOP employee and seeks money damages | Chandler filed suit before administrative tort claim was finally denied; failure to exhaust FTCA administrative remedies | FTCA claim dismissed for failure to exhaust administrative remedies under 28 U.S.C. § 2675(a) |
| Whether § 1983/PLRA exhaustion satisfied | Chandler alleges constitutional/medical care claims under § 1983 | No administrative remedies specific to the Feb. 27 incident were pursued; PLRA requires exhaustion of available remedies | § 1983/PLRA claims dismissed for failure to exhaust available administrative remedies under 42 U.S.C. § 1997e(a) |
| Whether court may grant unopposed dispositive motion under local rule | Chandler did not respond to motion; local rule could permit deeming motion conceded | Defendants rely on Local Civ. R. 7(b) to treat motion as conceded | Court declined to grant solely as conceded, reviewed merits due to controlling D.C. Cir. precedent and dismissed on substantive grounds |
| Whether district court has jurisdiction over contract claim | Chandler alleges BOP breached contract and seeks $200,000 | Contract claim seeks damages above $10,000, so Tucker Act jurisdiction lies with Court of Federal Claims | Contract claim dismissed for lack of subject‑matter jurisdiction in district court (exclusive jurisdiction for >$10,000 lies with Court of Federal Claims) |
Key Cases Cited
- McNeil v. United States, 508 U.S. 106 (1993) (FTCA requires administrative exhaustion before filing suit)
- Porter v. Nussle, 534 U.S. 516 (2002) (PLRA exhaustion applies to all inmate suits about prison life)
- Woodford v. Ngo, 548 U.S. 81 (2006) (PLRA requires proper exhaustion complying with procedural rules)
- Ross v. Blake, 136 S. Ct. 1850 (2016) (courts may not excuse failure to exhaust; exhaustion is mandatory)
- Jones v. Bock, 549 U.S. 199 (2007) (exhaustion is an affirmative defense for defendants to plead and prove)
- United States v. Mitchell, 463 U.S. 206 (1983) (sovereign immunity principle and waiver by statute govern suits against the United States)
- Cohen v. Board of Trustees of the Univ. of the District of Columbia, 819 F.3d 476 (D.C. Cir. 2016) (cautions against granting dispositive motions solely as conceded under Local Civ. R. 7(b))