Pumphrey v. Coakley, 5:15-cv-14430

Plaintiff William C. Pumphrey, then an inmate at FCI–Beckley, brought a Bivens action alleging a pattern of harassment and abuse (e.g., intrusive music, door banging, threats, assault) by multiple FCI–Beckley staff.
He claimed resulting anxiety, dental damage, headaches, and other injuries, and named the warden and staff as defendants.
The United States moved to dismiss or for summary judgment arguing (1) failure to exhaust administrative remedies under the PLRA, (2) failure to state a claim, (3) inability to recover emotional damages without physical injury, and (4) qualified immunity.
The Magistrate Judge issued a Proposed Findings and Recommendation (PF&R) recommending dismissal for failure to exhaust administrative remedies.
Pumphrey objected, alleging he repeatedly attempted to file grievances, that BOP SENTRY tracking was unreliable, and that staff obstructed or destroyed his filings.
The district court reviewed the PF&R, overruled Pumphrey’s objections (finding his allegations unsupported), adopted the PF&R, granted the Defendants’ motion, and dismissed the case for failure to exhaust.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Pumphrey exhausted administrative remedies under the PLRA before filing suit	He repeatedly filed grievances/appeals and attempted to comply; rejections, lost/blocked mail prevented exhaustion	BOP records and declarations show grievances were rejected and not properly appealed; remedies available were not exhausted	Court held Pumphrey failed to exhaust; dismissal granted
Whether administrative remedies were “unavailable” because staff obstructed or destroyed filings	Staff blocked, destroyed, or failed to mail grievances, preventing exhaustion	No evidence supports interference; plaintiff continued to file many submissions	Court found interference allegations conclusory and unsupported; remedies were available
Reliability of SENTRY and defendants’ declarations as proof of non-exhaustion	SENTRY is fallible; "garbage in, garbage out"; declarations unreliable	Declarations from records custodians accurately track filings; records show rejections and lack of appeals	Court accepted declarations and records as credible; plaintiff’s contrary assertions insufficient
Whether other defenses (failure to state claim, physical-injury rule, qualified immunity) required resolution	Plaintiff maintained claims were substantive and supported	Defendants raised additional defenses but primarily relied on PLRA non-exhaustion	Court dismissed on PLRA grounds and adopted PF&R; other defenses not reached on the merits

Bivens v. Six Unknown Named Agents of Fed. Bureau of Narcotics, 403 U.S. 388 (establishing Bivens remedy for constitutional violations by federal officers)
Woodford v. Ngo, 548 U.S. 81 (PLRA requires proper exhaustion of available administrative remedies)
Porter v. Nussle, 534 U.S. 516 (exhaustion requirement applies to inmate civil actions)
Dale v. Lappin, 376 F.3d 652 (grievance procedure is unavailable if prison officials prevent access)
Mitchell v. Horn, 318 F.3d 523 (unavailability due to official interference excuses exhaustion)
Jones v. Bock, 549 U.S. 199 (failure to exhaust is an affirmative defense; partial exhaustion principles)
Estelle v. Gamble, 429 U.S. 97 (pro se pleadings entitled to liberal construction in civil-rights suits)
Thomas v. Arn, 474 U.S. 140 (standard of review for magistrate judge recommendations)
Orpiano v. Johnson, 687 F.2d 44 (general/conclusory objections insufficient to avoid deferential review)
Loe v. Armistead, 582 F.2d 1291 (pro se liberal construction precedent)