Christians v. Young
4:20-cv-04083
D.S.D.Jul 7, 2025Background
- Mark Christians, a pro se inmate, filed a civil rights suit under 42 U.S.C. § 1983 against several South Dakota prison officials alleging Eighth Amendment violations due to inadequate nutrition and related retaliation claims.
- The court had previously granted in part and denied in part defendants’ summary judgment motion; several claims remained for trial, particularly those alleging inadequate caloric intake and improper meal portions during Christians’ incarceration.
- Christians filed multiple post-summary judgment motions, styled as objections or requests for reconsideration under Federal Rules of Civil Procedure 59(e) and 60, challenging the adverse portions of the court’s order.
- Christians also moved for a preliminary injunction to require defendants to provide a medically ordered cardiac diet, citing ongoing cardiovascular health concerns, but the court denied this on the grounds that it was unrelated to the claims at issue in the lawsuit.
- Christians did not provide sufficient evidence that he had exhausted administrative remedies for certain claims, and failed to properly support his opposition with specific record citations as required by local rules.
- Christians sought reconsideration of various denials, but the court found no grounds to alter its prior rulings.
Issues
| Issue | Plaintiff’s Argument | Defendant’s Argument | Held |
|---|---|---|---|
| Relief under Rules 59(e), 60(a), 60(b)(1), 60(b)(6) | Court erred or made a mistake in summary judgment order; argued exceptional circumstances | No mistake or extraordinary circumstance; order accurately reflects the court’s prior reasoning | Denied; no basis for relief under any cited rule |
| Exhaustion of Administrative Remedies | Argued substantial compliance with grievance process, and asserted issues with document handling | Christians did not attach necessary documents to grievances; failed to meet procedural requirements | Denied; claim barred for failure to exhaust |
| Retaliation Claims | Re-argued original opposition to summary judgment, citing his own declaration and submitted documents | Plaintiff failed to properly cite or submit evidence in the record, did not overcome summary judgment | Denied; insufficient evidence to create material fact |
| Preliminary Injunction for Cardiac Diet | Requested injunction for specific cardiac diet per doctor’s order, citing ongoing health issues | Relief seeks to add new claim not in amended complaints; unrelated to adjudicated issues | Denied; injunctive relief unrelated and untimely |
Key Cases Cited
- Kocher v. Dow Chem. Co., 132 F.3d 1225 (8th Cir. 1997) (Rule 60(a) only corrects mistakes to accurately reflect court’s actual decision)
- Broadway v. Norris, 193 F.3d 987 (8th Cir. 1999) (Rule 60(b)(1) not for simple reargument on merits)
- Harley v. Zoesch, 413 F.3d 866 (8th Cir. 2005) (Rule 60(b) is for extraordinary relief, only on showing exceptional circumstances)
- Barge v. Anheuser-Busch, Inc., 87 F.3d 256 (8th Cir. 1996) (Court not required to search record for genuine issues of material fact)