Chandler v. Federal Bureau of Prisons
Civil Action No. 2016-2091
| D.D.C. | Apr 17, 2017Background
- Plaintiff Johnny Ray Chandler, incarcerated at ADX Florence, sent three "cop outs" to a female staff member that led Sgt. D. Bilbrey to issue an incident report charging him with stalking (Prohibited Act Code 225).
- Chandler filed administrative remedies challenging the incident report: Warden responded, then the Regional Office responded, and an appeal to the Office of General Counsel was pending; he did not file an administrative tort claim with the BOP.
- Chandler sued Bilbrey (in his individual capacity) and the Federal Bureau of Prisons seeking $100,000, originally filing in D.C. Superior Court and later removed to federal court.
- Defendants certified Bilbrey acted within the scope of employment, so the court treated the monetary claim as one under the Federal Tort Claims Act (FTCA) against the United States.
- The BOP administrative process consists of an informal step plus formal appeals to the Warden, Regional Director, and Office of General Counsel; FTCA requires presentation of an administrative tort claim to the agency before suing.
- The court found Chandler failed to exhaust administrative remedies under both the FTCA (no tort claim filed) and the Prison Litigation Reform Act (PLRA) because he filed suit before completing the BOP four-step grievance process.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether plaintiff exhausted administrative remedies under the FTCA before suing for money damages | Chandler argued his administrative submissions relating to the incident report were sufficient | Defendants argued Chandler never filed an administrative tort claim required by FTCA §2675(a) | Court held Chandler failed to present an administrative tort claim; FTCA exhaustion required; dismissal granted |
| Whether plaintiff exhausted administrative remedies under the PLRA before filing suit | Chandler filed grievance steps but brought suit before completing all levels | Defendants argued PLRA requires completion of available prison administrative remedies (proper exhaustion) before suit | Court held Chandler filed his complaint prematurely (had not completed the four-step BOP process); PLRA exhaustion lacking |
| Whether the claim for money damages is against the United States (scope of employment) | Chandler sued Bilbrey individually and sought money from BOP and Bilbrey | Defendants certified Bilbrey acted within scope of employment, converting the claim to an FTCA claim against the U.S. | Court treated the damages claim as an FTCA claim against the United States |
| Whether the case should be transferred for improper venue given plaintiff's filing location | Chandler requested transfer to proper federal district | Defendants argued venue improper in D.C.; opposed transfer given plaintiff's litigation history | Court declined to transfer and dismissed for failure to exhaust, noting plaintiff's vexatious litigation history influenced transfer decision |
Key Cases Cited
- United States v. Mitchell, 463 U.S. 206 (sovereign immunity and waiver principles)
- Richards v. United States, 369 U.S. 1 (scope of FTCA waiver context)
- McNeil v. United States, 508 U.S. 106 (FTCA exhaustion is mandatory)
- Porter v. Nussle, 534 U.S. 516 (PLRA exhaustion requirement applies to all prisoner suits)
- Jones v. Bock, 549 U.S. 199 (exhaustion is an affirmative defense; procedural compliance required)
- Woodford v. Ngo, 548 U.S. 81 (proper exhaustion requires compliance with procedural rules)
- Booth v. Churner, 532 U.S. 731 (PLRA exhaustion required regardless of relief available administratively)
- Jackson v. District of Columbia, 254 F.3d 262 (PLRA exhaustion applied to suits about conditions of confinement)