Scott v. Christensen
3:23-cv-00585
| N.D. Ind. | Aug 26, 2025Background
- Channing Lamonte Scott, an inmate at Westville Correctional Facility, sued the Warden in his official capacity seeking permanent injunctive relief to address severe infestations of mice, ants, roaches, and spiders, alleging Eighth Amendment violations.
- The Warden moved for summary judgment, arguing that Scott failed to exhaust his available administrative remedies regarding his claims of infestation before filing suit.
- Westville had an established three-step grievance process: (1) formal grievance, (2) Level I appeal to the warden, and (3) Level II appeal to the Department Grievance Manager.
- Evidence showed Scott had used the grievance process for other complaints but never filed or fully exhausted a grievance specifically related to pest infestation.
- Scott contended that his informal and formal grievances regarding infestation were ignored or lost by prison staff, rendering the remedies unavailable.
- The court needed to determine whether Scott's actions satisfied the exhaustion requirement or whether his remedies were truly unavailable due to the prison's conduct.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Did Scott exhaust administrative remedies? | He submitted informal/formal grievances that were ignored/lost | He never filed or completed a grievance about infestation | Scott did not exhaust remedies |
| Were remedies unavailable due to prison inaction? | Remedies were unavailable because grievances were ignored | Remedies remained available through further procedural steps | Remedies were still available |
| Is strict compliance with grievance process required? | Strict compliance should not apply if ignored | Strict compliance is required except if process wholly unavailable | Strict compliance required |
| Did any grievance submitted address infestation claims? | Other grievances show intent to exhaust | No grievance put prison on notice of infestation claim | No grievance addressed infestation |
Key Cases Cited
- Anderson v. Liberty Lobby, Inc., 477 U.S. 242 (summary judgment standard: genuine dispute of material fact)
- Perez v. Wisconsin Dep’t of Corr., 182 F.3d 532 (exhaustion mandatory before filing suit)
- Kaba v. Stepp, 458 F.3d 678 (remedies unavailable if process truly obstructed by staff)
- Dole v. Chandler, 438 F.3d 804 (process is unavailable if staff prevent exhaustion)
- Lockett v. Bonson, 937 F.3d 1016 (strict compliance with exhaustion required)
- Maddox v. Love, 655 F.3d 709 (grievance must alert prison to the precise alleged problem)
- Bowers v. Dart, 1 F.4th 513 (grievance must not be disconnected from the lawsuit’s claim)