J.D. Turner v. Sgt. Knight
J.D. Turner v. Sgt. Knight - 1472 C.D. 2016
| Pa. Commw. Ct. | Feb 24, 2017Background
- Jeffrey D. Turner, a state prisoner, sued multiple Department of Corrections officers for events at SCI‑Rockview; only his Eighth Amendment excessive‑force claim against Mondy, Taylor and John Doe #4 (Remaining Defendants) remained.
- Turner alleged that on July 12, 2013 the Remaining Defendants slammed him into walls and threatened his life in the RHU strip cage.
- Remaining Defendants moved for summary judgment under 42 Pa.C.S. § 6602(e) (PLRA) arguing Turner failed to exhaust administrative remedies under DC‑ADM 804; affidavits said no timely grievance naming them was filed.
- Turner relied on Grievance 481695 (filed Oct. 11, 2013) and a July 28, 2013 call to a sexual‑abuse hotline as evidence of exhaustion; the grievance did not name the Remaining Defendants and was rejected as untimely.
- The trial court concluded Turner failed to timely file a DC‑ADM 804 grievance naming the Remaining Defendants and that the PREA directive (DC‑ADM 008) did not apply to the Remaining Defendants or replace the grievance process; it granted summary judgment and dismissed with prejudice.
- The Commonwealth Court affirmed, holding exhaustion was not satisfied and summary judgment was proper.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Turner exhausted administrative remedies under DC‑ADM 804 before filing suit | Turner: filing Grievance 481695 and calling the Sexual Abuse Hotline show exhaustion | Defendants: no timely grievance naming the Remaining Defendants was filed; grievance was untimely and did not identify them | Held: No — Turner failed to file a timely grievance under DC‑ADM 804 naming the Remaining Defendants; exhaustion not satisfied |
| Whether the PREA grievance process (DC‑ADM 008) satisfied exhaustion for this claim | Turner: Hotline call and PREA policy evidence of exhaustion | Defendants: PREA applies to sexual‑abuse matters and does not substitute for DC‑ADM 804 here; hotline related to a different incident and did not name defendants | Held: No — PREA/Hotline did not exhaust remedies for the Remaining Defendants or the alleged conduct at issue |
| Whether dismissal with prejudice was appropriate for failure to exhaust under PLRA § 6602(e) | Turner: argued trial court erred in finding failure to exhaust | Defendants: PLRA requires dismissal where exhaustion lacking; summary judgment proper | Held: Yes — dismissal with prejudice affirmed under PLRA for failure to exhaust administrative remedies |
| Whether the trial court erred as a matter of law in granting summary judgment | Turner: challenged trial court's ruling | Defendants: summary judgment standard satisfied because no genuine issue of material fact on exhaustion | Held: No error — summary judgment affirmed (standard of review applied; no disputed material fact on exhaustion) |
Key Cases Cited
- Morgalo v. Gorniak, 134 A.3d 1139 (Pa. Cmwlth. 2016) (describing DOC grievance system and exhaustion requirement)
- McCray v. Department of Corrections, 872 A.2d 1127 (Pa. 2005) (prison grievance process as forum for inmate complaints about confinement)
- Kittrell v. Watson, 88 A.3d 1091 (Pa. Cmwlth. 2014) (exhaustion requires completion of grievance steps including appeal to superintendent and DOC)
- Manley v. Fitzgerald, 997 A.2d 1235 (Pa. Cmwlth. 2010) (standard of review for summary judgment)