Daniel Matthews v. J. Taylor, 20-36008

Background

Plaintiff Daniel Matthews, an Oregon state prisoner, sued Oregon Department of Corrections (ODOC) officials under 42 U.S.C. § 1983 alleging failure to process grievances, retaliation, denial of due process, interference with mail/access to courts, and excessive force during a suicide-response.
At issue were Matthews’ alleged failure to exhaust administrative remedies; his claim that the grievance process was unavailable because of fear of retaliation; and discrete acts by grievance coordinator N. Sobotta and mailroom/administrative-segregation staff.
Matthews asserted Sobotta forced him to alter dates on two grievances and that ODOC’s limits on grievances per week/month impeded his access to the process.
He also alleged mailroom officials lost or censored a friend’s declaration, hindering post-conviction relief, and that segregation officers used excessive force while responding to his suicide attempt.
The district court granted summary judgment for all defendants. The Ninth Circuit affirmed, finding (among other things) failure to exhaust, no objective showing of fear-based unavailability, lack of retaliatory or due-process violations by Sobotta or mailroom staff, and insufficient evidence of malicious excessive force.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Failure to exhaust administrative remedies	Matthews argues he did not need to exhaust because the grievance process was effectively unavailable	Defendants contend Matthews failed to file required grievances before suit	Affirmed for defendants; Matthews failed to exhaust under 42 U.S.C. § 1997e(a)
Availability of grievance process due to fear of retaliation	Matthews claims he feared retaliation and thus process was unavailable	Defendants say no evidence of actual or objectively reasonable fear	Court held fear-of-retaliation excuse unsupported by record (McBride standard)
Grievance coordinator conduct (retaliation/due process)	Sobotta forced non-substantive date changes and denied grievances improperly	Sobotta says changes were non-substantive, denials had legitimate reasons and advanced penological goals	Court found no First Amendment chill, no due-process liberty interest in grievance procedure, and legitimate penological reasons for actions
Mailroom / access-to-courts & retaliation	Matthews alleges mail was ripped/misplaced and loss of a declaration hindered post-conviction relief	Defendants deny mishandling or retaliatory motive and note no showing of prejudice to litigation	Summary judgment proper: no evidence of retaliation/censorship and no showing how lost declaration impaired ability to obtain relief (Christopher/Lewis)
Excessive force by segregation officials	Matthews claims force used maliciously during suicide-response	Defendants say force was reasonable to prevent suicide and not malicious	Court held plaintiff produced no evidence of malicious/sadistic intent; summary judgment for defendants
Supervisory liability (J. Frazier)	Liability based on supervisory responsibility for subordinates’ alleged conduct	Defendants: no underlying constitutional violation, so no supervisory liability	Affirmed: supervisory claim fails because no underlying constitutional violation (Keates standard)

Key Cases Cited

Albino v. Baca, 747 F.3d 1162 (9th Cir. 2014) (prisoner must exhaust available administrative remedies)
McBride v. Lopez, 807 F.3d 982 (9th Cir. 2015) (fear of retaliation only excuses exhaustion if fear is actually held and objectively reasonable)
Rhodes v. Robinson, 408 F.3d 559 (9th Cir. 2005) (retaliation claim elements and First Amendment chilling test)
Woodford v. Ngo, 548 U.S. 81 (2006) (proper exhaustion requires compliance with procedural rules)
Ramirez v. Galaza, 334 F.3d 850 (9th Cir. 2003) (no protected liberty interest in prison grievance procedures)
Chappell v. Mandeville, 706 F.3d 1052 (9th Cir. 2013) (analysis of atypical and significant hardship for due-process claims)
Wood v. Yordy, 753 F.3d 899 (9th Cir. 2014) (standards for mail censorship and retaliation claims)
Christopher v. Harbury, 536 U.S. 403 (2002) (access-to-courts claim requires showing of actual injury to litigation rights)
Lewis v. Casey, 518 U.S. 343 (1996) (prisoners must show actual injury to demonstrate denial of access to courts)
Hudson v. McMillian, 503 U.S. 1 (1992) (excessive force standard: malicious and sadistic purpose vs. good-faith effort to maintain safety)
Clement v. Gomez, 298 F.3d 898 (9th Cir. 2002) (excessive force analysis in prison context)
Keates v. Koile, 883 F.3d 1228 (9th Cir. 2018) (supervisory liability requires an underlying constitutional violation)