Luther Stone v. Sheila Johnson
713 F. App'x 103
3rd Cir.2017Background
- Plaintiff Luther C. Stone, an inmate at SCI‑Mercer, alleged defendants removed him from a Therapeutic Community (T.C.) and forced him into sex‑offender treatment (SOP) despite no sex‑offense conviction.
- Stone claimed the change occurred in 2013 and that completion of SOP was later made a parole prerequisite.
- He sued under 42 U.S.C. § 1983 asserting violations of the First, Fifth, Eighth, and Fourteenth Amendments.
- Defendants moved to dismiss; the Magistrate Judge granted the motion on statute‑of‑limitations grounds and the dismissal was appealed.
- The Third Circuit affirmed on an alternative ground: Stone failed to exhaust administrative remedies because his April 8, 2015 grievance did not fairly raise the 2013 conduct and specific claims in his complaint.
- The court emphasized the PRLA exhaustion purpose: give prison officials a fair opportunity to address grievances and create an administrative record.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Stone exhausted administrative remedies under the PRLA | Stone contended his April 8, 2015 grievance sufficed to exhaust and preserve his claims about forced SOP and removal from T.C. | Defendants argued the grievance challenged only a parole denial and broadly complained of negligence, failing to fairly present the 2013 T.C. removal and SOP claims. | Held: Not exhausted — grievance did not fairly notify officials of the 2013 events or specific claims, so dismissal was proper. |
| Whether dismissal could be affirmed on statute‑of‑limitations grounds | Stone argued his claims were timely (implicit). | Defendants maintained claims were time‑barred. | Court did not decide statute‑of‑limitations because failure to exhaust provided an independent affirming ground. |
| Pleading standard applicability to pro se prisoner | Stone relied on pro se leniency in pleading. | Defendants relied on Rule 12(b)(6) standards and exhaustion rules. | Court applied liberal pro se standard but still required sufficient facts and proper exhaustion under PRLA. |
| Whether prison grievance satisfied required level of detail | Stone claimed grievance was adequate. | Defendants argued grievance lacked dates, events, and specific claim references required by DC‑ADM 804. | Held: Grievance failed to meet the system’s procedural content requirements and thus did not properly exhaust. |
Key Cases Cited
- Lake v. Arnold, 232 F.3d 360 (3d Cir. 2000) (standard of review for dismissal under Rule 12(b)(6))
- Warren Gen. Hosp. v. Amgen Inc., 643 F.3d 77 (3d Cir. 2011) (accept factual allegations and construe complaint in plaintiff’s favor on Rule 12(b)(6))
- Bell Atl. Corp. v. Twombly, 550 U.S. 544 (2007) (facial plausibility standard for pleadings)
- Haines v. Kerner, 404 U.S. 519 (1972) (pro se pleadings held to less stringent standards)
- Mala v. Crown Bay Marina, Inc., 704 F.3d 239 (3d Cir. 2013) (pro se plaintiffs still must allege sufficient facts)
- Woodford v. Ngo, 548 U.S. 81 (2006) (PRLA exhaustion requires fair opportunity for prison officials to address grievances)
- Jones v. Bock, 549 U.S. 199 (2007) (grievance detail is defined by prison procedures, not PLRA itself)