Eric Moss v. Buddy Harwood, 19 F.4th 614

Plaintiff Eric Moss, a pretrial detainee at Madison County Detention Center (Mar–Sep 2018), was placed on disciplinary lockdown after guards found a weapon in his cell on April 1, 2018; he claims he never received a disciplinary hearing.
Jail policy provided an inmate grievance procedure, including submission via written form or electronic kiosk; Moss did not file a written grievance about the hearing before suing on April 25, 2018.
Moss alleges jail staff denied him grievance forms and kiosk access while on lockdown, but the record shows he submitted multiple kiosk grievances and medical requests during lockdown (some submitted by other inmates using his PIN and later by him directly).
Moss also alleges constitutional violations from delays in receiving prescribed medications (thyroid med, Vyvanse for ADHD, Zoloft for PTSD): thyroid med arrived April 11 after a ~3-week delay; mental-health meds arrived May 8 after ~53 days; further delays continued until mid‑August.
The district court dismissed Moss’s grievance-access claim, allowed his disciplinary-hearing and medical claims to proceed, and later granted summary judgment for defendants: (1) Moss failed to exhaust administrative remedies under the PLRA because remedies were "available"; (2) defendants were not deliberately indifferent to his medical needs.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Moss was excused from PLRA exhaustion because grievance process was made unavailable while on lockdown	Officials denied him forms and kiosk access, thwarting exhaustion	Record shows Moss filed multiple kiosk grievances while on lockdown, so remedies were available	Remedies were "available"; Moss failed to exhaust his procedural‑due‑process claim; summary judgment affirmed
Whether defendants were deliberately indifferent to Moss's serious medical needs	Delays in providing thyroid and mental‑health meds posed substantial risk and caused harm (anxiety, suicidal thoughts, dangerous thyroid levels)	Defendants (non‑medical staff) promptly routed requests and scheduled appointments; no evidence they knew of and disregarded an obvious substantial risk	Even assuming objective risk, no evidence defendants subjectively recognized and disregarded it; summary judgment affirmed

Ross v. Blake, 136 S. Ct. 1850 (2016) (PLRA requires exhaustion of available remedies; remedies not required if "unavailable")
Woodford v. Ngo, 548 U.S. 81 (2006) (exhaustion gives prisons opportunity to correct mistakes)
Jones v. Bock, 549 U.S. 199 (2007) (PLRA exhaustion requirements and prisoner pleading rules)
Farmer v. Brennan, 511 U.S. 825 (1994) (deliberate indifference standard requires subjective knowledge of substantial risk)
Scinto v. Stansberry, 841 F.3d 219 (4th Cir. 2016) (deliberate indifference analysis for medical claims)
Kaba v. Stepp, 458 F.3d 678 (7th Cir. 2006) (availability of grievance process can vary by time/topic)
Hardy v. Shaikh, 959 F.3d 578 (3d Cir. 2020) (process is unavailable under PLRA only if inmate actually prevented from using it)