Jones v. Rahimi

Background

Monroe Jones brought a civil-rights action under 42 U.S.C. § 1983 against Rahimi, identified as a correctional deputy with the San Mateo Sheriff’s Department. Jones alleged that Rahimi used excessive force against him and retaliated against him by causing him to be transferred to another facility. Rahimi moved for summary judgment, arguing that Jones failed to exhaust the available administrative remedies. The motion was unopposed.

Jones alleged that on October 26, 2022, he gave Rahimi a complaint. According to Jones, Rahimi then ordered him to turn around, twisted his arm, handcuffed him while pushing upward, and pushed him out of the unit. Jones alleged that he was first placed in an isolated cell, moved to a restricted housing unit, and later transferred to administrative segregation at the Maguire Correctional Facility. Jones believed the transfer was retaliation for filing a complaint against Rahimi.

Rahimi gave a different account. He said that on October 27, 2022, Jones approached him about a mail-related complaint, was visibly agitated, and disturbed the housing unit. Rahimi said he ordered Jones moved to a holding cell, gently handcuffed him, and used no force. Rahimi also stated that he and Sergeant Dennis Loubal recommended transferring Jones to the Maguire Correctional Facility because of earlier housing-related issues. The Administrative Classification Unit approved the recommendation. Rahimi stated that Jones remained classified as a protective-custody inmate and was never placed in administrative housing.

Administrative grievances

The parties did not dispute that Jones filed grievances on May 17, May 18, July 9, September 13, September 22, October 5, and October 6, 2022, and that the sheriff’s office responded to each one. Rahimi stated that Jones filed no grievance concerning the handcuffing or transfer. The opinion states that there was no evidence of a grievance filed after the incident.

Jones asserted that Rahimi prevented exhaustion by tearing up his appeal before handcuffing him and arranging his transfer. The court observed that, even accepting this assertion as true, the complaint Jones allegedly gave Rahimi was written before the events underlying this lawsuit and therefore could not have described the later excessive-force or retaliation claims.

Legal standard and analysis

The Prison Litigation Reform Act requires prisoners to properly complete available administrative remedies before bringing a federal action about prison conditions. Proper exhaustion requires using all steps of the applicable process and following its deadlines and other procedural rules. The defendant bears the initial burden of showing that a remedy was available and that the prisoner did not use it. The burden then shifts to the prisoner to produce evidence that the remedy was effectively unavailable in the particular case.

Although a court may not grant an unopposed summary-judgment motion solely because the opposing party filed no response, it may grant the motion when the moving papers support judgment and do not reveal a genuine dispute over a material fact. Here, the court found that Rahimi showed an available grievance process and presented evidence that Jones did not exhaust any claim concerning the October 27 incident. The court further found that Jones’s conclusory explanation about the torn appeal was insufficient to create a triable factual dispute.

Disposition

The court granted Rahimi’s motion for summary judgment. It directed the clerk to terminate all pending motions, enter judgment in favor of Rahimi, and close the file.