Reid v. Balota, No. 19-1396 (7th Cir. 2020)
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Illinois inmate Reid sued under 42 U.S.C. 1983, alleging that a corrections officer used excessive force against him. The district court dismissed the action, concluding that Reid had not exhausted administrative remedies, as required by the Prison Litigation Reform Act, 42 U.S.C. 1997e(a).
The Seventh Circuit vacated. The prison’s communications were so obscure that they made further steps of its administrative process unknowable and, thus, unavailable to Reid. Reid had filed both a “standard grievance” and an emergency grievance, followed by an appeal to the Review Board, which was returned to him. Reid filed a second emergency grievance, which was again denied; the Board returned Reid’s subsequent appeal. The prison’s responses indicated that there was no conceivable next step for Reid. The grievance officer’s memorandum gave him conflicting messages. The Board told him that his appeal was missing specific documents but did not check the box specifying that those documents needed to be provided or that some explanation needed to be given for their absence. When the warden and the Board rejected the second grievance, neither mentioned a pending standard grievance or an ongoing Internal Affairs investigation. As far as Reid could tell, his standard grievance had been either lost in the shuffle or resolved against him.
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