Rucker v. Giffen, No. 20-1318 (2d Cir. 2021)
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Plaintiff filed suit under 42 U.S.C. 1983 alleging that officials at the Monroe County Jail denied him adequate medical care and subjected him to cruel and unusual punishment during his pretrial confinement. Plaintiff was ultimately admitted to the hospital where he was found to be in critical condition and was placed in a coma for over a month where he underwent serious surgeries. After his grievance was denied by the prison, plaintiff argued that administrative procedures were unavailable to him because he was hospitalized and in critical medical condition for over a month and therefore could not have filed a grievance within that five-day timeframe.
The Second Circuit reversed, concluding that administrative remedies are "unavailable" when (1) an inmate's failure to file for the administrative remedy within the time allowed results from a medical condition, and (2) the administrative system does not accommodate the condition by allowing a reasonable opportunity to file for administrative relief. In this case, administrative remedies were unavailable to plaintiff because he was hospitalized and in a critical medical condition during—and well past—the five-day timeframe to file a grievance according to the jail's grievance procedures. Furthermore, the prison made clear that it would not process any grievance filed past that five-day timeframe. Accordingly, the court remanded for the district court to consider plaintiff's claim on the merits.
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