Key v. Van Reil (INMATE 2), 1:22-cv-00461

Plaintiff David M. Key, an inmate, filed a pro se suit under 42 U.S.C. § 1983, alleging officers at Houston County Jail subjected him to excessive force and unconstitutional conditions.
Key claimed he was beaten while handcuffed and placed in a cell without toilet or sink, forcing him to urinate on the floor.
The Defendants responded with a special report, treating it as a motion to dismiss or for summary judgment based on failure to exhaust administrative remedies under the PLRA (42 U.S.C. § 1997e(a)).
The jail has a written grievance policy requiring inmates to grieve through a multistep process, including an appeals process up to three levels.
Key acknowledged the existence of the grievance procedure but claimed he never received the appropriate appeal papers, though he submitted over ten grievances.
The court reviewed both parties’ filings and treated the Special Report as a motion to dismiss for failure to exhaust; it dismissed the case without prejudice.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Key exhausted all available administrative remedies before filing suit	Filed grievances but did not receive appeal papers	Did not complete all steps of grievance process	No exhaustion; dismissal without prejudice required
Whether the grievance procedure was truly available to Key	Claimed lack of access to appeal forms	Procedure available and known to Key	Procedure was available; Key did not fully use it
Whether exceptions to exhaustion should apply	Implied procedural failure or denial by staff	No recognized exceptions in this context	No exceptions to PLRA's exhaustion requirement
Adequacy of Plaintiff's allegations regarding unavailability of remedies	Claimed grievances never made it to final appeal	Plaintiff did not pursue all available options	Allegations too vague to establish unavailability

Booth v. Churner, 532 U.S. 731 (Exhaustion required for all inmate suits, even where relief is not available through the prison process.)
Porter v. Nussle, 534 U.S. 516 (PLRA exhaustion requirement applies to all inmate suits about prison life.)
Woodford v. Ngo, 548 U.S. 81 (Proper exhaustion requires compliance with all critical procedural rules, including deadlines.)
Jones v. Bock, 549 U.S. 199 (Defendants bear burden of demonstrating lack of exhaustion.)
Ross v. Blake, 578 U.S. 632 (Describes when administrative remedies are considered unavailable under the PLRA.)