Charles Shumanis v. County of Lehigh
675 F. App'x 145
| 3rd Cir. | 2017Background
- Plaintiff Charles Shumanis, an inmate at Lehigh County Jail, sued under 42 U.S.C. § 1983 alleging jail staff condoned or failed to prevent a violent November 16, 2012 assault that caused severe physical and cognitive injuries.
- A no-contact order protected Shumanis from one attacker (Roberto Diaz); Shumanis alleges staff nonetheless put him in the same administrative room where the attack occurred.
- Defendants moved for summary judgment on the ground Shumanis failed to exhaust administrative remedies under the Jail’s Grievance Policy and Procedure (GPP) as required by the PLRA.
- The District Court found Shumanis knew of the GPP, that staff misconduct was grievable, and that Shumanis did not timely pursue the formal grievance steps required by the GPP; it entered summary judgment for defendants.
- The GPP text excludes grievances for "state and federal laws," raising an ambiguity whether claims alleging federal-law violations (like § 1983 claims) were "grievable" or rendered remedies unavailable.
- The Third Circuit vacated and remanded for further proceedings to allow the District Court to consider factual questions about the actual availability of remedies under the GPP in light of Supreme Court precedent on PLRA availability doctrine.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Shumanis exhausted administrative remedies under the PLRA | Shumanis argued administrative remedies were not "available" because the GPP excluded "state and federal laws," so he need not file a grievance | Defendants argued the GPP covers staff action and requires formal grievance exhaustion; plaintiff could not bypass grievance by alleging federal-law violations | Court vacated summary judgment and remanded for the District Court to make factual findings on actual availability of the GPP (e.g., dead-end, opaque, or thwarted process) |
| Proper interpretation of the GPP’s exclusion of "state and federal laws" | GPP language made remedies unavailable for federal-law issues | GPP should be read to bar only direct legal challenges to statutes, not complaints about staff conduct; allowing otherwise would thwart PLRA’s exhaustion goal | Court declined to resolve the issue on appeal and directed the District Court to consider factual and legal questions in first instance |
| Whether the District Court erred by resolving availability without full factual development | Shumanis contended factual development was required to assess availability | Defendants relied on District Court’s legal construction and factual findings to support summary judgment | Court held factual questions about availability may be necessary post-Ross and remanded for further proceedings |
| Allocation of the exhaustion burden | Shumanis asserted he reasonably believed grievance was unnecessary | Defendants asserted plaintiff’s failure to follow GPP bars suit until exhaustion | Court reiterated that failure to exhaust is an affirmative defense for defendants to plead and prove, and that availability is a factual/legal inquiry for district courts |
Key Cases Cited
- Jones v. Bock, 549 U.S. 199 (prisoner must exhaust available administrative remedies; failure to exhaust is an affirmative defense)
- Woodford v. Ngo, 548 U.S. 81 (proper exhaustion requires compliance with prison procedural rules)
- Booth v. Churner, 532 U.S. 731 (exhaustion requirement applies to claims seeking relief for prison conditions)
- Porter v. Nussle, 534 U.S. 516 (PLRA exhaustion applies to all inmate suits about prison life)
- Spruill v. Gillis, 372 F.3d 218 (prison grievance procedures define exhaustion requirements; interpretation akin to statutory construction)