Wright v. Inslee, 2:23-cv-00854

Brandon Wright, an inmate in the Washington Department of Corrections (DOC), filed suit alleging violations of the Americans with Disabilities Act (ADA) and Rehabilitation Act (RA) relating to access to education and library services in mental health units (RTUs) at two facilities: Washington State Penitentiary (WSP) and Monroe Correctional Complex (MCC).
Wright claimed inmates with mental illness in RTUs are denied equal access to education and library services compared to other inmates, disadvantaging them upon re-entry to society.
Wright sought only injunctive and declaratory relief against DOC officials in their official capacities.
Defendants moved for summary judgment, arguing mainly that Wright failed to exhaust administrative remedies as required by 42 U.S.C. § 1997e(a).
The Court examined whether Wright properly used available grievance processes as required by DOC policy and federal law, considering both facilities where Wright had been housed.
The central procedural posture: summary judgment motion by Defendants based on failure to exhaust remedies.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Exhaustion of administrative remedies under § 1997e(a)	Wright claims he made an ADA request and exhausted grievance at WSP and issues continued at MCC/SOU.	Defendants argue Wright failed to exhaust education-related grievances at MCC/SOU after transfer.	Not exhausted at MCC/SOU; summary judgment granted
Scope and sufficiency of grievances (state-wide vs. facility)	Wright contends grievances at WSP should cover similar issues at MCC/SOU and system-wide deficiencies.	Defendants argue grievances were specific to WSP, not applicable to MCC/SOU or statewide claims.	Grievance only covered WSP, not MCC/SOU or state-wide
Standing for injunctive relief after transfer	Wright seeks statewide injunctive relief for all RTUs.	Defendants claim Wright no longer has standing for WSP claims after transfer to MCC/SOU.	No standing for WSP claims after transfer
Sufficiency of informal actions (communications/"kites")	Wright claims informal written communications satisfy the exhaustion requirement.	Defendants argue only formal DOC grievance processes count for exhaustion, not informal communications.	Informal actions do not satisfy exhaustion

Porter v. Nussle, 534 U.S. 516 (2002) (holding § 1997e(a) requires exhaustion of all administrative remedies prior to suit)
Booth v. Churner, 532 U.S. 731 (2001) (exhaustion requirement applies regardless of the relief offered through administrative procedures)
Woodford v. Ngo, 548 U.S. 81 (2006) (proper exhaustion requires compliance with all procedural rules of the grievance process)
Jones v. Bock, 549 U.S. 199 (2007) (failure to exhaust is an affirmative defense, and the burden is on defendants)
Griffin v. Arpaio, 557 F.3d 1117 (9th Cir. 2009) (grievance must notify officials of the problem to satisfy the exhaustion requirement)
DeFunis v. Odegaard, 416 U.S. 312 (1974) (lack of standing to pursue injunctive relief for no longer applicable conditions)