Chandler v. Federal Bureau of Prisons
249 F. Supp. 3d 271
| D.D.C. | 2017Background
- Plaintiff Johnny Ray Chandler, Sr., a federal inmate at ADX Florence, filed a complaint in D.C. Superior Court alleging BOP and former Director Charles Samuels maliciously interfered with his access to the courts by refusing to pay postage for certified mail to serve process.
- He sought $75,000 in damages and a permanent order requiring the BOP to pay certified-mail postage for indigent inmates.
- Defendants removed the case to federal court and moved to dismiss for failure to exhaust administrative remedies.
- BOP declarant attested Chandler filed multiple administrative remedy requests between July and December 2016, but none and no tort claim raised the allegations in this complaint.
- The court notified Chandler that an opposition was due; he did not timely oppose (he filed an unrelated abeyance motion earlier).
- The court treated exhaustion under both the FTCA (no administrative tort claim filed) and the PLRA (no properly exhausted BOP remedies) as dispositive and dismissed the action for failure to exhaust.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether plaintiff exhausted administrative remedies under the FTCA before suing for monetary damages | Chandler alleges BOP action by Samuels gives rise to tort damages and sued in federal court | Defendants show no administrative tort claim was presented to BOP as required by 28 U.S.C. § 2675(a) | Dismissed for failure to exhaust FTCA administrative remedies |
| Whether plaintiff exhausted available BOP administrative remedies under the PLRA for prison-related claims | Chandler contends denial of certified-mail postage interfered with access to courts, warranting suit | Defendants show the BOP administrative remedy requests that reached final step did not raise these allegations; PLRA requires proper exhaustion | Dismissed for failure to exhaust PLRA remedies |
| Whether the complaint can proceed against Samuels personally or under FTCA despite exhaustion defects | Plaintiff seeks damages and injunctive relief tied to Samuels/BOP conduct | Defendants removed and certified Samuels acted within scope; court treats claim as FTCA claim against the United States, subject to FTCA exhaustion rules | Claim construed as FTCA claim and dismissed for non-exhaustion |
| Whether Local Civil Rule 7(b) alone warrants granting defendants’ unopposed dismissal motion | Plaintiff failed to timely oppose motion to dismiss | Defendants argue motion may be treated as conceded; court mindful of Cohen caution about automatic grant of unopposed dismissal | Court did not rely solely on concession; addressed merits and dismissed on exhaustion grounds |
Key Cases Cited
- Cohen v. Bd. of Trs. of the Univ. of the District of Columbia, 819 F.3d 476 (D.C. Cir. 2016) (cautioning against automatic grants of unopposed dismissal motions under local rule)
- McNeil v. United States, 508 U.S. 106 (1993) (FTCA bars suit until administrative remedies are exhausted)
- Porter v. Nussle, 534 U.S. 516 (2002) (PLRA exhaustion requirement applies to all prisoner suits about prison conditions)