France v. Bloomfield

Background

Michael R. France, a California state prisoner at San Quentin State Prison, filed this civil-rights action under 42 U.S.C. § 1983. He represented himself. His amended complaint alleged that officials confiscated his legal paperwork while moving him to administrative segregation, interfering with his ability to respond in another civil case. He also alleged that officials deliberately disregarded his safety by transferring people who had COVID-19 to San Quentin and deliberately disregarded his medical needs by failing to treat his asthma and hepatitis C.

Defendants moved for summary judgment, which asks whether the evidence shows that no important factual dispute requires a trial and that the moving party is entitled to judgment under the law. France opposed the motion and requested summary judgment for himself based on a California COVID-19 prison case.

Exhaustion requirement

The court applied the Prison Litigation Reform Act, which requires prisoners to complete available prison administrative remedies before filing federal lawsuits. The process must be properly completed, including compliance with applicable deadlines and other important procedural rules.

Access-to-courts claim

The court considered two grievances concerning France’s legal paperwork. The first grievance, identified in the opinion’s subsection heading as grievance number 14186, did not raise the confiscation-of-paperwork or access-to-courts issue in France’s appeal. The court therefore found that grievance did not exhaust that claim.

France’s second grievance, number 47576, raised the claim that officials took his property and legal paperwork and caused another case to be dismissed. But the prison’s appeals office did not deny that appeal until February 13, 2021, more than two months after France filed his amended complaint on December 11, 2020. Because the claim was not fully exhausted before the amended complaint was filed, the court granted summary judgment for defendants on the access-to-courts claim.

Deliberate-indifference claims

For the medical-care claim concerning asthma and hepatitis C, defendants submitted evidence that France had never submitted health-care grievances or appeals. France did not specifically dispute that evidence or provide contrary evidence. The court therefore granted summary judgment for defendants on that claim.

For the COVID-19 claim, the court considered grievance number 46805. France filed that grievance on September 29, 2020, and appealed the prison’s response. The appeals office did not respond by the December 25, 2020 deadline. The court treated the claim as not exhausted until at least that deadline, which was two weeks after France filed his amended complaint. The court therefore granted summary judgment for defendants on the COVID-19 claim as well.

Disposition

The court granted defendants’ motion for summary judgment on exhaustion grounds. The ruling was without prejudice to France filing his exhausted claims in a new case. The court also granted defendants’ motions to stay discovery and substitute counsel. It denied as moot defendants’ motion to amend their answer. Because summary judgment was appropriate for defendants based on failure to exhaust, the court did not reach France’s request for summary judgment on the merits.

Effect of the order

The order ended the claims presented in this action on the stated exhaustion ground, while expressly leaving France able to file his exhausted claims in a new case.