Griffin v. Bryant

In 2015, Matthew Griffin was seriously injured when North Carolina prison officials denied him accommodations for his diagnosed vision impairment, sedated him against his will, left him alone despite his calls for help and denied him much-needed medical attention when he fell to the ground and dislocated his shoulder.

Under the Prison Litigation Reform Act (PLRA), a prisoner must exhaust all “available” administrative remedies before filing a lawsuit by ensuring perfect compliance with a prison’s grievance rules. When Mr. Griffin attempted to use the prison’s grievance system to complain about his involuntary sedation and the injury he suffered as a result, prison officials denied his grievance not because it lacked merit but because the prison kept a grievance Mr. Griffin filed pending, blocking his ability to submit the new grievance until the deadline to do so passed.

When Mr. Griffin turned to the federal courts for help, the district court dismissed his claims for failure to exhaust administrative remedies, despite his evidence of unavailability. The Roderick & Solange MacArthur Justice Center (MJC) represented Mr. Griffin on appeal in the Fourth Circuit, arguing that under both the plain text of the PLRA and prior U.S. Supreme Court precedent, the prison administrative process was not available to Mr. Griffin.

In support of MJC’s position, a coalition of organizations dedicated to the rights of incarcerated individuals, led by the ACLU, filed an amicus brief, emphasizing the considerable barriers to exhaustion, the ability of prison officials to manipulate the exhaustion systems and the way in which an overreading of exhaustion blocks prisoners from accessing the courts.

The Fourth Circuit reversed the district court’s decision and remanded for further proceedings. On the facts that the parties had presented, the Court expressed concerns that the prison’s grievance procedure was self-contradictory as written and inconsistently applied by prison officials. The Court further commented that Mr. Griffin had made a “compelling case” that the grievance procedure was not available to him, although it found that further factual development was required.

MJC is optimistic that with further facts presented, Mr. Griffin will finally get his claims heard on the merits.