Saddler, Jay v. Hewitt, Jessica, 3:19-cv-00081

Background:

Plaintiff Jay Jasmine Saddler, a Wisconsin state prisoner formerly detained at Grant County Jail and later at DCI, RCI, and WCI, sued multiple county and state officials alleging inadequate medical care for a left-hand knife injury (Eighth and Fourteenth Amendment claims).
Defendants split into two groups: three state prison officials (Herrington, Johnson, Zacharias) and nine Grant County jail staff; both groups moved for summary judgment arguing Saddler failed to exhaust administrative remedies under the PLRA.
Saddler filed some ICRS complaints at WCI in 2019 but did not raise the 2017 DCI/RCI treatment issues until long after transfers and filed this federal suit before completing the DOC secretary-level appeal.
At Grant County Jail, Saddler submitted five grievance forms in late 2016, but none specifically put jail officials on notice that he was dissatisfied with medical care for the hand injury.
Saddler argued (1) his grievances exhausted the claims, (2) officials had actual knowledge, and (3) grievance procedures were unavailable due to his injury, transfers, or alleged staff discouragement; the court found these arguments unsupported by the record.
Holding: the court granted both groups’ summary judgment motions, denied Saddler’s cross-motions, and dismissed the case without prejudice for failure to exhaust (dismissal likely moot on timeliness for future grievances).

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Saddler exhausted DOC (state) administrative remedies for claims based on 2017 treatment	Saddler contends WCI grievances and appeals put defendants on notice and exhausted claims	State defendants show no complaint raising DCI/RCI treatment was fully pursued before suit; later WCI complaints were untimely or did not encompass earlier incidents	Court: No exhaustion — complaints did not properly raise or timely exhaust claims against state defendants; summary judgment for state defendants
Whether Saddler exhausted Grant County Jail grievance process for county claims	Saddler argues December 2016 grievances referenced his prior injury and thus exhausted jail claims	County defendants show submitted grievances did not mention dissatisfaction with medical care for the hand; process requires Inmate Grievance Form submission addressing the issue	Court: No exhaustion — county grievances did not put officials on notice about medical-care claims; summary judgment for county defendants
Whether actual knowledge by defendants cures failure to follow administrative rules	Saddler asserts defendants knew of his condition so exhaustion should be excused	Defendants argue PLRA requires procedural compliance regardless of notice so officials must have been given a chance to correct	Court: Rejected plaintiff’s actual-knowledge argument; exhaustion requirement not satisfied by alleged awareness alone
Whether grievance process was "unavailable" (excusing exhaustion)	Saddler claims physical inability to write, transfers, and alleged staff discouragement made process unavailable	Defendants and record show Saddler filed multiple grievances and gave no specific evidence of sabotage or incapacity preventing use	Court: Process not shown to be unavailable; bald assertions insufficient; exhaustion required and not met

Key Cases Cited

Perez v. Wis. Dep’t of Corr., 182 F.3d 532 (7th Cir. 1999) (exhaustion narrows disputes and allows administrative resolution before litigation)
Woodford v. Ngo, 548 U.S. 81 (2006) (exhaustion requires using all steps and complying with procedural rules)
Pozo v. McCaughtry, 286 F.3d 1022 (7th Cir. 2002) (plaintiff must file complaints and appeals where and when agency rules require)
Davis v. Mason, 881 F.3d 982 (7th Cir. 2018) (failure to exhaust is an affirmative defense for defendants to prove)
Ford v. Johnson, 362 F.3d 395 (7th Cir. 2004) (suit filed before administrative remedies completed must be dismissed)
Ross v. Blake, 136 S. Ct. 1850 (2016) (prisoner need not exhaust unavailable remedies; ‘‘opaque’’ or nonfunctional procedures may be unavailable)
Cannon v. Washington, 418 F.3d 714 (7th Cir. 2005) (exhaustion gives officials an opportunity to take corrective action pre-litigation)
Bordelon v. Bd. of Educ. of the City of Chicago, 811 F.3d 984 (7th Cir. 2016) (summary judgment requires concrete factual affidavits, not bald assertions)