Savoie v. Oliver, 2:23-cv-11357

Plaintiff Joseph Savoie, an inmate, alleged Eighth Amendment violations by prison staff at Saginaw Correctional Facility regarding deliberate indifference to his medical needs.
Specific complaints included delays and denial of medical care, with Health Information Manager Sharyl Chamberlin allegedly involved in delaying treatment and approvals.
Savoie’s grievances did not specifically name Chamberlin but referenced issues with "whoever is running Health Care Services."
Magistrate Judge recommended dismissal of Chamberlin due to Savoie’s failure to exhaust administrative remedies as required by the Prison Litigation Reform Act (PLRA) and MDOC grievance policy.
Savoie later filed a Rule 60(b)(2) motion to modify the judgment, claiming that new evidence revealed Chamberlin was responsible for scheduling his offsite medical appointments.
The district court considered whether this "new evidence" justified relief from its prior judgment dismissing Chamberlin without prejudice.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Savoie exhausted administrative remedies as to Chamberlin	He lacked knowledge of Chamberlin’s role but referenced her indirectly in grievances	Plaintiff did not name or sufficiently identify Chamberlin in grievances	Savoie did not exhaust remedies for Chamberlin; dismissal affirmed
Whether new evidence about Chamberlin’s role justifies relief under Rule 60(b)(2)	Discovery revealed Chamberlin’s responsibility for scheduling; grievance should cover her	New evidence insufficient; grievance did not mention scheduling or connect to Chamberlin	New evidence would not have changed outcome; Rule 60(b)(2) relief denied
If failure to name Chamberlin in a grievance should be excused if Savoie didn't know her identity	Savoie could not have known who to name due to lack of info	Naming other staff but not Chamberlin fails PLRA rules; no fair notice	Court sympathetic but administrative process still not satisfied
Whether the grievance gave fair notice regarding Chamberlin	Reference to “whoever is running Health Care Services” should suffice	Reference too vague; no clear connection to Chamberlin or her actions	Reference was too attenuated to give fair notice

Woodford v. Ngo, 548 U.S. 81 (2006) (administrative remedies must be properly exhausted, complying with agency procedural rules)
Jones v. Bock, 549 U.S. 199 (2007) (prisoners must properly exhaust administrative remedies, but strict naming is not always required)
Burton v. Jones, 321 F.3d 569 (6th Cir. 2003) (grievances must provide fair notice of the alleged wrongdoing)