Johnson v. Meyer

Background

Joseph Jamaul Johnson, who was representing himself and was incarcerated, brought a civil-rights action under 42 U.S.C. § 1983. He alleged that prison officials violated the Eighth Amendment by failing to protect him from an attack and by failing to address his serious medical needs.

Johnson alleged that correctional sergeants Oyarzabal and Cermeno knew he had an enemy in Facility C but allowed him to be released there. He also alleged that correctional officers Matias and Salgado and sergeant Perez watched while four inmates attacked him. Johnson alleged that Dr. Sawyer and nurse Villanueva failed to arrange physical therapy recommended after surgery for injuries he suffered during the incident.

The defendants moved for summary judgment based on failure to exhaust administrative remedies. Exhaustion requires a prisoner to complete available prison grievance procedures before bringing a federal lawsuit about prison conditions.

Failure-to-Protect Claims

Johnson filed a grievance about his release to Facility C and the staff members’ alleged failure to stop the attack. The grievance proceeded through the third level, the highest level of California’s prison appeal system. Prison officials investigated the matter, reviewed reports, questioned personnel, and decided the grievance on its merits.

The defendants argued that Johnson failed to identify the responsible staff members by name and that his descriptions were too vague. The court rejected that argument. It found that officials had refused to provide documents that would have helped Johnson identify the staff members, that Johnson identified Oyarzabal, and that the third-level reviewer decided the grievance on its merits instead of rejecting it for failure to name the wrongdoers.

The court concluded that Johnson exhausted the available administrative remedies for both sets of failure-to-protect allegations. It denied summary judgment on those claims. The court did not decide whether the defendants actually violated the Eighth Amendment; it set a schedule for a later motion addressing the merits.

Medical-Care Claim

Johnson filed a health-care grievance stating that he was in pain, had undergone facial surgery, and needed medical care. The grievance did not identify Dr. Sawyer or nurse Villanueva, did not allege that they denied physical therapy, and did not proceed to the required headquarters-level review.

The court held that the grievance did not provide the names and descriptions of involvement required by the California regulations in effect during the relevant period. It also held that Johnson did not show that prison officials prevented him from completing the grievance process. The defendants therefore met their burden of showing that Johnson failed to exhaust his administrative remedies for the medical-care claim.

The court granted summary judgment in favor of Dr. Sawyer and nurse Villanueva on that claim and dismissed the claim without prejudice to Johnson filing a new action if he properly exhausts the administrative remedies.

Other Orders and Disposition

The defendants’ motion for summary judgment was granted in part and denied in part. Summary judgment was granted on the medical-care claim and denied on the failure-to-protect claims against Oyarzabal, Cermeno, Perez, Matias, and Salgado.

The court allowed further discovery on the failure-to-protect claims and required the remaining defendants to respond to Johnson’s earlier discovery requests and disclose the incident report for the July 16 events. The court also set deadlines for a further summary-judgment motion, Johnson’s opposition, and any reply.