Coleman v. Bowden, 2:14-cv-00726

Background

Coleman, a Florida prisoner, sued six prison officials under 42 U.S.C. § 1983 after a cellmate attacked him on October 9, 2012, alleging Eighth Amendment deliberate indifference and a First Amendment retaliation claim against Sgt. Walker.
Relevant grievances: Oct. 23, 2011 grievance about property handling; Nov. 10, 2011 “emergency” grievance to FDOC rep Bowden; Dec. 14, 2012 institutional grievance (returned for raising multiple issues); Jan. 18, 2013 appeal to the Secretary (procedurally defective).
District court dismissed claims against Bowden for failure to state a claim and dismissed other deliberate-indifference claims for failure to exhaust administrative remedies, but permitted the retaliation claim against Walker to proceed.
The court denied Coleman’s motion to compel medical/mental-health records (found irrelevant to the remaining claim) and denied leave to file a second amended complaint as unduly delayed and prejudicial.
The district court granted summary judgment for Sgt. Walker on the retaliation claim because Walker lacked responsibility for cell assignments and Coleman was not housed in Walker’s unit after the grievance; the Eleventh Circuit affirmed.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Dismissal of claims against Bowden (12(b)(6))	Bowden’s review/denial of grievances and role in FDOC liability supports a § 1983 claim	Mere grievance review and supervisory status are insufficient for personal participation or causation	Affirmed — complaint failed to plausibly allege Bowden’s personal participation or causal role
Dismissal for failure to exhaust deliberate-indifference claims (PLRA)	Procedural barriers, mental-health confinement, and threats excused exhaustion	Institutional grievance was noncompliant; direct appeal to Secretary was improper; no exemption shown	Affirmed — Coleman failed to properly exhaust; threats or confinement did not excuse exhaustion here
Motion to compel medical/mental-health records and property slips	Records relevant to claims and discovery	Records irrelevant to the sole surviving retaliation claim; property slips not properly requested	Affirmed — discovery denial not an abuse of discretion; records irrelevant
Denial of leave to file second amended complaint	Sought to add/clarify claims before SJ decision	Amendment would unduly delay and prejudice defendants after close of discovery and pending summary judgment	Affirmed — denial proper for undue delay/prejudice
Summary judgment on retaliation claim against Walker	Walker retaliated by placing Coleman with enemies or leaving property unsecured after Coleman’s grievance	Walker lacked control over cell assignments and Coleman was not in Walker’s unit after the grievance; new factual theory unpled	Affirmed — new theory cannot be raised at summary judgment; no causal link and Walker entitled to SJ

Key Cases Cited

Ashcroft v. Iqbal, 556 U.S. 662 (2009) (pleading must state plausible claim)
Bell Atlantic Corp. v. Twombly, 550 U.S. 544 (2007) (plausibility standard for complaints)
Farmer v. Brennan, 511 U.S. 825 (1994) (Eighth Amendment deliberate indifference standard)
Woodford v. Ngo, 548 U.S. 81 (2006) (PLRA requires proper exhaustion of administrative remedies)
Lane v. Philbin, 835 F.3d 1302 (11th Cir. 2016) (elements of deliberate indifference)
Dimanche v. Brown, 783 F.3d 1204 (11th Cir. 2015) (proper exhaustion requires following critical procedural rules)
Turner v. Burnside, 541 F.3d 1077 (11th Cir. 2008) (test when threats render grievance process unavailable)
Gilmour v. Gates, McDonald & Co., 382 F.3d 1312 (11th Cir. 2004) (plaintiff may not raise new claims at summary judgment)
Farrow v. West, 320 F.3d 1235 (11th Cir. 2003) (elements of prison-retaliation claim)
Bryant v. Rich, 530 F.3d 1368 (11th Cir. 2008) (court may resolve factual disputes about exhaustion)