(PC)Maea v. Pfeiffer
1:22-cv-00362
E.D. Cal.Jun 9, 2025Background
- Ernest Maea, a state prisoner, filed a 42 U.S.C. § 1983 complaint alleging excessive force and state-law claims against several prison officials.
- Defendants moved for summary judgment on the ground that Maea failed to exhaust administrative remedies as required by the Prison Litigation Reform Act (PLRA).
- The magistrate judge recommended granting the motion in part, finding Maea exhausted some grievances but not others; both sides objected to parts of these findings.
- The district judge conducted a de novo review under 28 U.S.C. § 636(b)(1), addressing objections related to exhaustion of Bane Act claims, administrative barriers in segregation, and supervisory liability of certain defendants.
- Ultimately, the court dismissed claims against two defendants for failure to exhaust, but ruled claims against three others—including Bane Act and Eighth Amendment claims—could proceed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Exhaustion of Bane Act claim | Allegations provide notice; specific threats not required | Grievances lacked threats/intimidation details | Plaintiff exhausted available remedies on Bane Act claim as to some defendants |
| Administrative barriers in segregation | Difficulties in segregation made appeal process unavailable | Plaintiff had opportunity to exhaust but failed | General difficulties insufficient; no triable fact that appeals unavailable |
| Exhaustion as to supervisory liability (Pfeiffer & Felder) | Similar to Monell claims; inmates not expected to detail supervisor involvement | No facts in grievances linked supervisors to alleged wrongs | Plaintiff did not exhaust administrative remedies as to Pfeiffer and Felder |
| Summary judgment disposition | MAEA's claims should proceed against all defendants | Only exhausted claims should proceed | Summary judgment for Pfeiffer and Felder; claims proceed against Martinez, Anderson, Goree |
Key Cases Cited
- Reese v. Cnty. of Sacramento, 888 F.3d 1030 (9th Cir. 2018) (Bane Act requires specific intent; threats/coercion need not be independent of constitutional violation)
- Fordley v. Lizarraga, 18 F.4th 344 (9th Cir. 2021) (PLRA requires grievances to alert prison to the nature of the wrong for exhaustion)
- Marella v. Terhune, 568 F.3d 1024 (9th Cir. 2009) (Unavailability of grievance process if appeals not allowed absent inaccurate denial reason)