Robinson v. Schrag

Background

Terence Lee Robinson filed a self-represented action under 42 U.S.C. § 1983, a law allowing claims against state officials for violations of federal rights. He alleged that Pelican Bay State Prison officers J. Schrag, A. Maylin, T. Gray, and J. Taylor used excessive force against him on September 6, 2016, in violation of the Eighth Amendment. Robinson alleged that officers pinned his arms, placed a body on him, and put him in a headlock.

That same day, Robinson received a rules violation report accusing him of battery on a peace officer. He was found guilty on April 12, 2017. The record identified two grievances that addressed the incident. The first sought dismissal of the disciplinary report and guilty finding, asserting that Robinson had not resisted when officers restrained him. The second challenged the cancellation of the first grievance and requested that it receive third-level review, mentioning possible monetary compensation.

Legal standard

The Prison Litigation Reform Act requires a prisoner to exhaust available prison administrative remedies before filing a federal action concerning prison conditions. In California’s system, exhaustion generally requires submitting a prison grievance and proceeding through all three levels of review. Proper exhaustion also requires following applicable deadlines and other procedural rules.

The defendants moved for summary judgment. Summary judgment is granted when the record shows no genuine dispute over a fact important to the outcome and the moving party is entitled to judgment as a matter of law. Robinson did not oppose the motion.

Court’s analysis

The court first explained that the rules violation report itself did not exhaust administrative remedies because California’s process requires a complaint submitted on the designated grievance form and reviewed through three levels.

The court then considered the two grievances. It found that the first grievance focused on Robinson’s conduct and the allegedly false disciplinary report. It did not allege or imply that correctional officers had used excessive force. The second grievance focused on the cancellation of the first grievance. Although the request for monetary compensation could indicate that Robinson intended to bring a civil-rights lawsuit, the court concluded that it did not identify an excessive-force claim. A request for damages can relate to many civil-rights claims, not only excessive force.

The court agreed that prison officials had improperly cancelled the first grievance. The court reasoned that, if that grievance had raised an excessive-force claim, the improper cancellation could have treated the claim as exhausted. But the improper cancellation did not exhaust claims that the grievance itself had not raised. Because neither grievance alerted prison officials to a possible excessive-force claim, the court held that Robinson’s excessive-force claim was unexhausted.

Disposition

The court granted the defendants’ motion for summary judgment and dismissed the action for failure to exhaust administrative remedies without prejudice to refiling after exhaustion. The Clerk was directed to enter judgment for the defendants against Robinson. Judge Haywood S. Gilliam, Jr. signed the order.