Corey Crouch v. Richard Brown, 27 F.4th 1315

Corey Crouch was confined in Indiana restrictive/administrative solitary status from Feb 2016 to Dec 2019 (≈4 years).
During that time he received at least 35 Reports of Classification Hearing (ROCHs) and 21 statutorily required 30-day reviews.
Crouch did not file appeals from any ROCH or 30-day review; he had previously used the ROCH appeal process before solitary confinement.
The 30-day reviews did not include appeal instructions until February 2019, when language was added explaining a 10-working-day classification-appeal procedure.
Crouch sued under 42 U.S.C. § 1983 claiming his prolonged solitary confinement did not receive meaningful review; the district court granted summary judgment for defendants for failure to exhaust administrative remedies and dismissed without prejudice.
The Seventh Circuit treated the dismissal as effectively final (amendment would be futile) and affirmed summary judgment, holding Crouch failed to exhaust available remedies.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Crouch exhausted administrative remedies under the PLRA	Crouch argued remedies were not meaningfully available and thus he need not exhaust	Defendants argued he had multiple opportunities (ROCHs and 30-day reviews) and failed to appeal	Held: Crouch failed to exhaust; he had ≥56 opportunities and did not pursue available appeals, so summary judgment affirmed
Whether 30-day reviews were appealable / whether added appeal language made remedies "available"	The added appeal language was meaningless without a formal policy change; reviews were not appealable decisions	Defendants: the added language and existing classification appeal process made 30-day reviews appealable; Crouch could attach reviews to ROCH appeals	Held: The appeal language made the remedy available; no evidence of affirmative misconduct or that appeals were thwarted
Whether the district court's dismissal without prejudice was appealable	Implied challenge to appellate jurisdiction over an apparently non-final dismissal	Defendants: dismissal without prejudice is ordinarily non-final	Held: Under Kaba/Hoskins line, dismissal for failure to exhaust is effectively final where amendment would be futile; appellate jurisdiction exists

Porter v. Nussle, 534 U.S. 516 (applies PLRA exhaustion to all inmate suits about prison life)
Woodford v. Ngo, 548 U.S. 81 (requires proper exhaustion and compliance with procedural rules)
Ross v. Blake, 578 U.S. 632 (remedies must be "available" to be required; defines unavailability)
Booth v. Churner, 532 U.S. 731 (defining exhaustion principles in prisoner suits)
Dole v. Chandler, 438 F.3d 804 (prison officials cannot use their own mishandling to defeat exhaustion)
Kaba v. Stepp, 458 F.3d 678 (prison misconduct can render remedies unavailable; burden on defendants to prove availability)
Curtis v. Timberlake, 436 F.3d 709 (exhaustion can include informal practices; disputed fact issues can preclude summary judgment)
Pozo v. McCaughtry, 286 F.3d 1022 (administrative-exhaustion rules not limited to written rules)