Jackson v. Schnell

Background

Tony Dejuan Jackson brought this action under 42 U.S.C. § 1983, alleging that conditions at the Minnesota Correctional Facility in Stillwater violated his constitutional rights. His allegations concerned harmful levels of lead dust, inadequate ventilation, smoke from Canadian wildfires, and excessive heat and humidity.

The defendants moved for summary judgment. Summary judgment is a ruling entered when the record shows no genuine dispute over facts important to the outcome and the moving party is entitled to judgment under the law. The defendants argued that the Prison Litigation Reform Act required Jackson to exhaust the administrative remedies available through the prison’s grievance system before filing this action.

Magistrate Judge’s Recommendation

United States Magistrate Judge Douglas L. Micko recommended granting the defendants’ motion. The recommendation found that MCF-Stillwater had a grievance process requiring an inmate to begin with a “kite,” proceed through the chain of command if necessary, file a formal grievance, and, if dissatisfied with the response, appeal to the Minnesota Department of Corrections’ Central Office.

The recommendation found that the defendants’ evidence showed Jackson had not filed a grievance concerning the issues in his complaint. It also found no evidentiary support for Jackson’s contention that the grievance process was unavailable to him. The recommendation rejected his arguments that he could not obtain relief, that response deadlines prevented a timely appeal, and that the defendants had failed to provide all of his kites.

District Court’s Review

Jackson objected to the recommendation. He argued that the court should examine complaints and other filings from his prior federal cases and that prison officials had prevented him from using the grievance process. The court explained that, in deciding summary judgment, it was required to consider cited materials and was not required to search voluminous filings for evidence that might support a party’s position.

The court found no genuine factual dispute that Jackson had failed to fully exhaust the available grievance process. It also found no evidence that prison officials had prevented him from using that process. In particular, the court noted that the grievance-tracking system contained no grievances from Jackson concerning the issues alleged in this case, including grievances that may have been improperly filed.

The court reviewed specific objections without deference and reviewed the remainder of the recommendation for clear error. It found no clear error and agreed that the defendants were entitled to summary judgment. The court further stated that, because the time for Jackson to pursue the administrative remedies had expired, his claims were subject to dismissal with prejudice.

Order

The court accepted the Report and Recommendation; overruled Jackson’s objections; granted the defendants’ motion for summary judgment; granted Jackson’s motions to submit additional arguments and to have his affidavit considered; dismissed the matter with prejudice; and denied as moot Jackson’s motion to amend the scheduling order.