Morgan, who is proceeding without counsel, filed suit against Sheriff Lane alleging improper confinement and unlawful detainment at the Bartholomew County Jail. The court previously screened Morgan's complaint and allowed him to proceed on due process claims against the sheriff for the alleged unlawful detention.
In his motion filed Tuesday, Sheriff Lane argues that Morgan never utilized the jail's internal grievance process before filing his federal civil rights lawsuit. Under the Prison Litigation Reform Act, inmates must exhaust all available administrative remedies before pursuing claims in federal court. As Lane's counsel stated in the filing, Morgan's claims are 'barred by the failure to exhaust administrative remedies as required by 42 U.S.C. § 1997e(a).'
The sheriff's motion requests that the court 'dismiss his claims in their entirety' based on this procedural failure. The PLRA's exhaustion requirement serves as a complete bar to litigation when inmates bypass available internal grievance procedures.
Morgan was incarcerated at the Bartholomew County Jail during the time period covered by his complaint and amended complaint. The case stems from what Morgan characterizes as his improper confinement at the facility. He is currently housed at Plainfield Correctional Facility.
The sheriff's legal team argues that because Morgan failed to pursue available administrative remedies through the jail's grievance system, his federal court action is premature and must be dismissed regardless of the underlying merits of his detention claims.
The exhaustion requirement under the PLRA has been a frequent source of dismissals in prisoner civil rights cases. Courts have consistently held that inmates must complete the administrative process even when they believe it would be futile, with limited exceptions for cases where administrative remedies are truly unavailable.
The motion is supported by a memorandum of law that was filed contemporaneously. Morgan will have an opportunity to respond to the sheriff's arguments before the court rules on the summary judgment motion.