Administrative – Prison Litigation Reform Act – Failure to Exhaust Administrative Remedies

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Appellant timely and specifically objected to the magistrate judge’s findings that he failed to exhaust his administrative remedies, and that Defendants violated his constitutional rights.

We vacated the district court’s orders and remanded for further consideration.

Onaje Kudura Seabrook appealed the district court’s order accepting the magistrate judge’s recommendation and granting summary judgment to Defendants, and the court’s order overruling Seabrook’s objections to the magistrate judge’s recommendation. The magistrate judge recommended granting Defendants’ motion for summary judgment on Seabrook’s 42 U.S.C. § 1983 action because Seabrook failed to exhaust administrative remedies under the Prison Litigation Reform Act, 42 U.S.C. § 1997e(a), and qualified immunity shielded Defendants. The district court overruled Seabrook’s April 3 amended objections to the magistrate judge’s report, granted summary judgment to Defendants, and concluded that objections dated March 13 and filed after entry of the dismissal order were substantially similar to the April objections; the court dismissed the March 13 objections as moot.

The record discloses that Seabrook timely and specifically objected to the magistrate judge’s findings that he failed to exhaust his administrative remedies, and that Defendants violated his constitutional rights. Importantly, Seabrook asserted that he gave his original objections to prison staff on March 13, 2024, and prison staffed stamped the envelope as received and postmarked the envelope on March 14, 2024, within the extended deadline for filing objections. Seabrook also timely filed amended objections in April. The district court, however, had received and reviewed only Seabrook’s April objections before accepting the magistrate judge’s recommendation and granting summary judgment to Defendants. Once the district court received Seabrook’s March 13 objections, the court determined that they were substantially similar to the April objections and concluded that the March 13 objections were therefore moot. Because the March 13 objections were timely filed and were not substantially similar to the April objections—and indeed included objections not raised in the April objections—we concluded that the March 13 objections were not moot and were properly before the district court.

Accordingly, we vacated the district court’s orders and remanded for consideration of Seabrook’s March 13 objections in the first instance. We expressed no opinion on the merits of Seabrook’s claims.

Vacated and remanded.

Seabrook v. Carter (Lawyers’ Weekly No. 003-010-25, 5 pp.) (Per Curiam) Appealed from the U.S. District Court for the District of South Carolina at Aiken (Richard Mark Gergel, J.) Onaje Kudura Seabrook, Appellant Pro Se; Charles Clifford Rollins, Richardson Plowden & Robinson, PA, Columbia, South Carolina, for Appellees. U.S. Court of Appeals for the Fourth Circuit Unpublished