Sartoris v. Primecare Medical CEO and Staff, 3:23-cv-00640

Edward Sartoris, a pretrial detainee at Monroe County Correctional Facility (MCCF), filed a civil rights action under 42 U.S.C. § 1983 alleging unconstitutional conditions of confinement due to exposure to mold, contaminated water, and MRSA.
Sartoris argued these conditions led to health problems, including migraines, breathing disorders, and a MRSA infection.
He claimed he filed grievances about these issues, but did not receive adequate responses or resolutions from facility staff.
The remaining defendants—MCCF Warden, Deputy Warden, a Sergeant, Monroe County, and unnamed John Doe individuals—moved for summary judgment based on lack of exhaustion of administrative remedies and lack of evidence supporting Sartoris’s claims.
The Court also considered dismissing the action against the John Doe defendants for failure to timely identify or serve them under Rule 4(m).

Issue	Plaintiff's Argument	Defendant's Argument	Held
Exhaustion of Administrative Remedies	Sartoris claims he attempted to exhaust, but grievances disappeared or were unaddressed.	Defendants argue Sartoris did not fully exhaust the MCCF grievance process.	Plaintiff did not exhaust; summary judgment for defendants.
Conditions of Confinement (Fourteenth Amendment)	Sartoris alleges unsanitary conditions (mold, water) caused health problems.	Defendants deny environmental hazards, cite DOC inspections and cleaning protocols.	No evidence of unconstitutional conditions; summary judgment for defendants.
Deliberate Indifference	Sartoris asserts officials knowingly disregarded risks.	Defendants state they took reasonable steps, and no risk was documented.	No evidence officials acted with deliberate indifference.
Dismissal of John Doe Defendants (Rule 4(m))	Plaintiff did not identify or serve John Does but sought to keep claims.	Defendants argue for dismissal due to lack of service and identification.	John Doe defendants dismissed.

Anderson v. Liberty Lobby, Inc., 477 U.S. 242 (explaining that only disputes of material fact preclude summary judgment)
Celotex Corp. v. Catrett, 477 U.S. 317 (party seeking summary judgment must show absence of genuine issues)
Bell v. Wolfish, 441 U.S. 520 (defining unconstitutional punishment under the Fourteenth Amendment)
Farmer v. Brennan, 511 U.S. 825 (deliberate indifference standard for conditions of confinement)
Wilson v. Seiter, 501 U.S. 294 (subjective requirement for deliberate indifference)