Chuck W. Adams, Charles E. Howard v. ArvinMeritor, Inc.
2015 Ind. App. LEXIS 741
| Ind. Ct. App. | 2015Background
- Adams and Howard, incarcerated at DOC’s Correctional Industrial Facility (CIF), worked in a Meritor-operated brake shop under a DOC contract; Adams alleged pay far below prevailing wages and suffered a work-related injury with allegedly inadequate medical care.
- Adams sued Meritor and certain State defendants for unpaid wages and sued Medical and CIF State defendants for personal injury/medical malpractice and deliberate indifference.
- Trial court granted Meritor and State defendants’ T.R. 12(B)(6) dismissal of the wage claim (holding no private right of action) and granted summary judgment to Medical and State‑CIF defendants on personal‑injury claims for failure to exhaust administrative remedies.
- On appeal the court addressed (1) whether Title 11 confers a private cause of action to enforce Chapter 7 prevailing‑wage requirements for offender employment by private enterprises, (2) whether Adams had to exhaust DOC administrative remedies for his medical claims, and (3) whether the trial court erred by denying Adams video or same‑day transport for a hearing.
- The court held the wage claim stated a private cause of action as of the date the complaint was filed (pre‑May 9, 2013 amendments that later exempted offenders), reversed dismissal of the wage claim, affirmed summary judgment on medical claims for failure to exhaust, and upheld denial of video/same‑day transport because Adams could submit documentary evidence and failed to timely secure alternate appearance options.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Title 11 (Ch. 7) gives inmates a private right of action to enforce the prevailing‑wage requirement | Adams: §11‑10‑7‑4 makes Chapter 7 enterprises "subject to laws governing similar enterprises" (including wage statutes), implying a private right to sue for unpaid wages | Meritor/State: Title 11 contains no explicit private cause of action; inmate claims against DOC programs are not subject to private suit absent explicit statutory authorization or constitutional violation | Court: Pre‑May 9, 2013 statutory scheme implied a private right to pursue unpaid wages against private employer under Chapter 7; reversed dismissal of wage claim (later legislative amendments curtailed that right) |
| Whether exhaustion of DOC grievance procedures was required for Adams’s medical/personal‑injury claims | Adams: DOC grievance process could not grant monetary relief and Executive Assistant could reject grievances seeking money, so no available administrative remedy | Medical/State‑CIF: PLRA and DOC Offender Grievance Process (OGP) provided an available remedy for medical complaints; exhaustion is required even if grievance cannot award money | Court: OGP was available; inability to obtain money did not make remedy unavailable; Adams failed to exhaust; summary judgment affirmed |
| Whether trial court erred by denying Adams’s motion to appear by video conference or same‑day transport for the dismissal/hearing | Adams: He had a right to be heard on motions and preliminary injunction; incarceration prevented in‑person attendance so court should have arranged his participation | Defendants/Court: Motion was untimely; court lacked resources for transport for civil case and needed advance notice to set up video conferencing; alternatives existed (documentary submission, telephone) | Court: No error — motion untimely, court attempted phone arrangements, Adams could participate via verified pleadings and documentary filings; denial affirmed |
Key Cases Cited
- Blanch v. Ind. Dep’t of Corr., 829 N.E.2d 505 (Ind. 2005) (no implied private right of action under several Title 11 provisions concerning prison discipline)
- Kimrey v. Donahue, 861 N.E.2d 379 (Ind. Ct. App. 2007) (trial courts lack jurisdiction over inmate statutory claims under Title 11 absent explicit private cause of action or constitutional violation)
- Booth v. Churner, 532 U.S. 731 (2001) (exhaustion requirement applies even where grievance cannot award requested money damages)
- Porter v. Nussle, 534 U.S. 516 (2002) (PLRA requires exhaustion of available administrative remedies for prisoner claims)
- Dole v. Chandler, 438 F.3d 804 (7th Cir. 2006) (purpose of exhaustion is to allow administrative process to run and possibly resolve claims)
- Caesars Riverboat Casino, LLC v. Kephart, 934 N.E.2d 1120 (Ind. 2010) (standard of review for T.R. 12(B)(6) motions)