Saeli v. Chautauqua County, No. 20-2340 (2d Cir. 2022)
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Plaintiff appealed from the district court’s ruling granting summary judgment on all claims to Defendants-Appellees Chautauqua County (“the County”) and Correction Officers (“the Officers”) in this civil rights suit concerning the County’s policy of handcuffing inmates in an allegedly painful manner and the Officers’ use of force in extracting Plaintiff from his cell at the Chautauqua County Jail (“the Jail”).
The Second Circuit held that the district court did not err in granting summary judgment on exhaustion grounds with regard to Plaintiff’s claims against the Officers, but that it did err in doing so with regard to his claim against the County. The court explained that that the district court was correct that Plaintiff failed to present sufficient evidence to create a genuine dispute of material fact as to whether he had submitted a timely grievance related to his claims against the Officers. The district court erred, however, in holding that the Chautauqua County Jail’s grievance policy applied to his separate claim against the County. By its plain terms, the grievance procedures did not apply to matters outside the jail captain’s control, such as the County handcuffing policy that Plaintiff challenges, and thus there were no administrative remedies for Plaintiff to exhaust with respect to that claim.
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