Todd Mattox v. Adam Edelman
851 F.3d 583
6th Cir.2017Background
- Todd Mattox, a Michigan prisoner, experienced recurrent chest pain beginning July 2011; outside cardiologists recommended cardiac catheterization and later prescribed Ranexa, a non-formulary drug.
- Corizon-employed clinicians (Drs. Pandya, Jordan, Borgerding, P.A. Neff, and previously Dr. Edelman) denied or delayed the procedures/medication; Mattox filed multiple MDOC grievances (JCF-1632, JCF-1747, JCF-1974, LCF-0355, LCF-0159) at different times.
- Mattox filed a § 1983 suit after exhausting earlier grievances against some defendants, later amending to add Ranexa-related claims against Pandya, Jordan, and Borgerding after exhausting additional grievances.
- The magistrate judge and district court dismissed the Ranexa claims for failure to exhaust (and dismissed Jordan sua sponte); the district court also dismissed Mattox’s claim against P.A. Neff for failure to state an Eighth Amendment claim.
- On appeal the Sixth Circuit considered (1) whether PLRA exhaustion bars adding claims exhausted after suit commencement via Rule 15(d) and (2) whether Mattox had alleged an objectively serious medical need re: Neff.
- The Sixth Circuit affirmed dismissal of Neff, reversed dismissal of Pandya, Jordan, and Borgerding (finding genuine issues as to exhaustion of later grievances), and remanded.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether PLRA bars adding claims exhausted after filing via Rule 15(d) | Mattox: Rule 15(d) allows supplementation for events after filing; PLRA purpose still satisfied because officials get notice before amendment | Defs: §1997e(a) "no action shall be brought" requires exhaustion before any suit includes the claim | Court: Rule 15(d) and PLRA are compatible where original complaint included at least one exhausted claim; supplemental claims exhausted post-filing may be added |
| Whether first three grievances exhausted Ranexa claims against Pandya | Mattox: earlier grievances put officials on notice of inadequate medication generally | Pandya: earlier grievances sought catheterization, did not mention Ranexa (not yet prescribed) | Court: first three grievances did not exhaust Ranexa claims against Pandya; summary judgment for Pandya reversed because later grievance (fifth) could exhaust |
| Whether fourth/fifth grievances exhausted claims against Jordan and Borgerding | Mattox: fourth named Jordan and requested Ranexa; fifth identified RMO later clarified as Borgerding | Jordan/Borgerding: grievances were filed after suit began and/or did not properly identify defendants | Court: a reasonable jury could find the fourth/fifth grievances sufficiently identified Jordan and Borgerding; dismissal for failure to exhaust reversed |
| Whether Mattox pleaded an objectively serious medical need re: P.A. Neff (Aug 14, 2011) | Mattox: symptoms were so obvious that need for emergency care was evident; need not show formal diagnosis | Neff: complaint shows no actual serious condition that night; later tests ruled out coronary disease | Court: Plaintiff failed to allege he actually needed emergency treatment on Aug 14; claim against Neff properly dismissed |
Key Cases Cited
- Jones v. Bock, 549 U.S. 199 (statutory "action" treated like "claim" for PLRA exhaustion)
- Woodford v. Ngo, 548 U.S. 81 (exhaustion required under PLRA)
- Farmer v. Brennan, 511 U.S. 825 (subjective component of deliberate indifference)
- Estelle v. Gamble, 429 U.S. 97 (Eighth Amendment deliberate indifference to medical needs)
- Blackmore v. Kalamazoo Cty., 390 F.3d 890 (6th Cir.) ("obvious medical need" theory requires showing actual need)
- Reed-Bey v. Pramstaller, 603 F.3d 322 (6th Cir.) (grievance must identify relevant defendants/issues per MDOC policy)
- Cannon v. Washington, 418 F.3d 714 (7th Cir.) (Rule 15 permits adding claims exhausted after suit filed when original suit had exhausted claims)
- Cox v. Mayer, 332 F.3d 422 (6th Cir.) (distinguished; plaintiff there had not exhausted any claims before filing)