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