Ninth Circuit Finds California Prisoner’s Administrative Remedies Effectively Unavailable
Joshua Franklin Snyder was a pretrial detainee at two Riverside, California, detention facilities. While there, Snyder complained about unsanitary living conditions. After filing several grievances, Snyder brought federal suit, alleging that jail conditions violated the Eighth Amendment to the United States Constitution.
The district court granted the defendants summary judgment and dismissed the action, finding that Snyder failed to exhaust all available administrative remedies before filing suit as required by 42 USC § 1997e(a) of the Prison Litigation Reform Act (PLRA). Prisoners are required to exhaust only available administrative remedies. See Jones v. Bock, 549 U.S. 199 (2007); and Ross v. Blake, 136 S.Ct. 1850 (2016).
The Ninth Circuit reversed, agreeing with Snyder that the generally available grievance process was effectively unavailable to him, making summary judgment inappropriate.
Noting that Riverside utilizes a four-level grievance process and Snyder exhausted only the first two stages, the Court found that to meet his burden under the PLRA, Snyder was required to show that the last two steps of the grievance process were effectively unavailable to him. The court concluded that Snyder made the requisite showing.
Taking the evidence in the light most favorable to Snyder, the court found that “a reasonable factfinder could conclude that the last two levels of the grievance process were effectively unavailable to Snyder because, once he reached that point in the process, he was directed by prison officials to essentially give up and start again.”
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Related legal case
Snyder v. Riverside Cty.
| Year | 2020 |
|---|---|
| Cite | 819 F. App’x 514 (9th Cir. 2020) |
| Level | Court of Appeals |
| Conclusion | Bench Verdict |