Garcia v. Heath, No. 22-367 (2d Cir. 2023)
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Plaintiff brought a Section 1983 claim against prison officials for their conduct during an electrical fire at Sing Sing Correctional Facility. Meanwhile, the prison officials claim that Plaintiff received a denial but failed to appeal. The district court determined that Plaintiff had not exhausted his administrative remedies and granted summary judgment to the officials. Plaintiff claimed that he received a denial and then appealed through the second and third stages of review.
The Second Circuit vacated. The court explained that drawing all reasonable inferences in Plaintiff’s favor, there is a genuine dispute of material fact as to whether Plaintiff exhausted his administrative remedies. The prison officials may have mistakenly failed to consolidate Plaintiff’s grievance with those of the other inmates who were affected by the electrical fire—in a possible violation of state regulations requiring full consolidation. Plaintiff’s declaration is consistent with a belief that his grievance was denied as part of the consolidated group of grievants. He may have appealed that denial, but the prison system might not have a record of his appeal because it failed to record the denial of his initial grievance in the first place. Plaintiff’s declaration—combined with (1) the undisputed evidence that he filed an initial grievance, (2) the absence of documentary evidence that his complaint was ever denied, and (3) the apparent failure of the prison officials to consolidate his complaint with those of the other inmates—creates a dispute of material fact as to whether Plaintiff actually did pursue all administrative remedies that were “available” to him. 42 U.S.C. Section 1997e(a).
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