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Sanders v. Purdom
2:23-cv-11413
E.D. Mich.
Jul 16, 2024
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Background

  • Plaintiff DeJhan Sanders, a prisoner at Macomb Correctional Facility, alleges constitutional violations by various prison staff under 42 U.S.C. § 1983.
  • Sanders’s complaint involves six claims against different defendants (e.g., excessive force, sexual harassment, retaliation, due process violations).
  • The defendants moved for summary judgment, arguing that some claims are barred by res judicata (prior lawsuit) and others for failure to exhaust administrative remedies as required by the PLRA.
  • The magistrate judge found Sanders properly exhausted administrative remedies for some, but not all, claims and identified a prior settlement that barred one claim.
  • The judge recommended partial summary judgment: some claims to proceed, others to be dismissed with or without prejudice depending on the reason.

Issues

Issue Plaintiff's Argument Defendant's Argument Held
Exhaustion of Administrative Remedies Sanders claims he exhausted all available MDOC grievance steps for each defendant and claim. Defendants argue Sanders failed to exhaust most claims except those against Saunders and Purdom. Sanders exhausted only claims against Saunders (Claim 2), Purdom (Claim 3), and possibly Webster (Claim 6); the rest dismissed for lack of exhaustion.
Res Judicata (Claim Preclusion) Sanders contends this case raises new issues despite a prior case involving the same defendants. Defendants assert Claim 1 is barred because it was addressed and resolved with prejudice in a prior lawsuit. Claim 1 against Purdom, Ling, and Martinez dismissed with prejudice due to prior settlement (res judicata).
Proper Identification of Defendants in Grievances Sanders argues minor errors (misspelling) should not bar exhaustion. Defendants claim claims are unexhausted if not naming proper defendants at Step I. Court finds spelling errors do not preclude exhaustion if sufficient info is provided and later corrected.
Claims Without Any Grievance Sanders asserts all underlying incidents are covered by some grievance. Defendants argue some claims (Claim 4, Claim 5) have no corresponding grievance and are thus unexhausted. Claims without any grievance (Claim 4, Claim 5) dismissed without prejudice for lack of exhaustion.

Key Cases Cited

  • Anderson v. Liberty Lobby, Inc., 477 U.S. 242 (summary judgment standard requires no genuine dispute of material fact)
  • Woodford v. Ngo, 548 U.S. 81 (administrative remedies must be properly exhausted under PLRA)
  • Jones v. Bock, 549 U.S. 199 (exhaustion defined by prison procedures, not PLRA sanctions)
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Case Details

Case Name: Sanders v. Purdom
Court Name: District Court, E.D. Michigan
Date Published: Jul 16, 2024
Docket Number: 2:23-cv-11413
Court Abbreviation: E.D. Mich.