Thank You For Submiting Feedback!
In Ex Parte Young, 209 U.S. 123, 28 S. Ct. 441, 52 L. Ed. 714 (1908), the Supreme Court created an exception to the Eleventh Amendment, which limits the power of federal courts to hear suits against a state, in holding that a suit challenging the constitutionality of a state official's action in enforcing state law is not an action against the state. However, the Eleventh Amendment, as interpreted by the Supreme Court, still bars actions against states for retroactive relief, whether that relief be in the form of damages or a declaration that a state officer violated a plaintiff's rights in the past. To decide whether the rule of Ex Parte Young avoids an Eleventh Amendment bar to suit, "a court need only conduct a 'straightforward inquiry into whether the complaint alleges an ongoing violation of federal law and seeks relief properly characterized as prospective.'"
Plaintiffs Christopher Varner, Eugene Griggs, and Cameron Maddox, all inmates or former inmates at the Augusta State Medical Prison ("ASMP"), filed their respective complaints alleging that they were subjects of an excessive force assault by correctional officers at ASMP in violation of the Eight and Fourteenth Amendments. Defendant ASMP officers filed motions to dismiss and a motion to sever. Defendants that were subject of Varner’s claims argued that Varner failed to exhaust his administrative remedies through the grievance procedure of Georgia Department of Correction's ("GDC"), as required by the Prison Litigation Reform Act, and therefore, Varner was barred from bringing the action. Moreover, defendants contended that plaintiffs’ claim for declaratory and injunctive relief should be dismissed for failure to state a claim because their request for declaratory relief was barred by the Eleventh Amendment and their request for injunctive relief was barred by the PLRA.
The Court noted that the Eleventh Circuit used a two-step process for analyzing exhaustion. First, the court would compare the factual allegations in the defendant’s motion to dismiss with those in the plaintiff’s response, and where a conflict existed, the court would take the plaintiff’s version of the facts as true. If, under that light, the defendant was entitled to dismissal for the plaintiff’s failure to exhaust administrative remedies, the complaint should be dismissed. In this case, the parties made diverging allegations over whether an administrative remedy was available to Varner. As such, the Court must take Varner's version of the facts as true. Accordingly, the Court must move to the second Turner step and make specific findings to resolve the parties' factual disputes regarding exhaustion. The Court held that while Varner filed grievances, each was filed at least seventeen months past deadline. These grievances cannot satisfy Varner's obligation to exhaust his administrative remedies because they were not "proper." The Supreme Court has made clear that proper exhaustion required compliance with the prison's administrative deadlines and critical procedural rules. Accordingly, defendants' motion to dismiss Plaintiff Varner's complaint for failure to exhaust administrative remedies under the PLRA is granted and Varner's claims were dismissed. Anent the second issue, the Court noted that the Eleventh Amendment barred actions against states for retroactive relief, whether that relief be in the form of damages or a declaration that a state officer violated a plaintiff’s rights in the past. In this case, however, the Court held that plaintiffs Griggs and Maddox were not seeking damages from either, only prospective declaratory injunctive relief against the defendants in their official capacities, as allowed under Ex Parte Young.