## Facts

- Eugene Griggs, Christopher Varner, and Cameron Maddox were inmates at Augusta State Medical Prison (ASMP) in Georgia.
- Each plaintiff alleged that, on a different occasion, ASMP correctional officers used excessive force against him, violating the Eighth and Fourteenth Amendments and giving rise to claims under 42 U.S.C. § 1983.
- The plaintiffs filed one joint lawsuit against multiple correctional officers and prison administrators, including supervisory officials, seeking damages and requesting relief aimed at stopping the alleged use of gratuitous force at the prison.
- The complaint framed the three assaults as part of a long-running “pattern and practice” at ASMP in which officers allegedly used force to inflict pain, including against inmates with serious physical or mental illnesses.
- To support the alleged pattern, the complaint described assaults on at least six other inmates and alleged that some of the same officers participated across incidents.
- Administrators allegedly failed to correct the alleged practice and minimized or discounted credible complaints of abuse.
- Under the Prison Litigation Reform Act (PLRA), inmates generally must complete the prison’s administrative grievance process before filing suit about prison conditions.
- The record at the motion stage reflected that Griggs and Maddox completed the grievance process, but Varner did not.
- Defendants moved to dismiss Varner’s claims for failure to exhaust administrative remedies and moved to sever the plaintiffs’ claims into separate actions, arguing the incidents were factually distinct and involved different officers and witnesses.

## Issues

1. Whether Varner’s § 1983 claims had to be dismissed under the PLRA, 42 U.S.C. § 1997e(a), because he failed to exhaust available administrative remedies (and whether a related internal investigation could substitute for exhaustion).
2. Whether the three inmates could proceed together under Federal Rule of Civil Procedure 20(a)(1) when each plaintiff’s excessive-force claim arose from a separate incident, even though the complaint alleged a prison-wide pattern and included overlapping defendants.
3. If joinder was improper, whether the court should sever the plaintiffs’ claims into separate actions under Rule 21.

## Decision

- The court dismissed Varner’s claims for failure to exhaust administrative remedies as required by the PLRA.
- The court rejected the argument that an internal investigation into the incident, standing alone, satisfied the PLRA’s exhaustion requirement.
- The court determined that the three plaintiffs’ excessive-force claims did not arise out of the same transaction, occurrence, or series of transactions or occurrences for Rule 20 purposes.
- The court granted severance, requiring the plaintiffs’ claims to proceed separately rather than in a single joined action.

## Legal Principles

- The PLRA requires prisoners to exhaust “such administrative remedies as are available” before filing a federal action concerning prison conditions; failure to exhaust requires dismissal of the unexhausted claims.
- PLRA exhaustion requires use of the prison’s formal grievance process; a prison’s internal investigation into an incident does not, by itself, replace that process.
- Under Rule 20(a)(1), multiple plaintiffs may join in one action only if their claims arise out of the same transaction or occurrence (or series of them) and share at least one common question of law or fact.
- Allegations that separate assaults reflect a general pattern at a prison do not automatically convert distinct events—occurring on different dates, involving different conduct and participants—into the same transaction or occurrence under Rule 20.
- Even when claims share similar legal theories and some overlapping defendants, courts may order severance under Rule 21 where the proof and witnesses for each plaintiff’s incident will largely differ and joint litigation would complicate case management.

## Conclusion

In *Griggs v. Holt*, the district court enforced the PLRA by dismissing Varner’s excessive-force claims because he did not complete the prison grievance process, holding that an internal investigation is not a substitute for exhaustion. The court also found the three inmates’ claims were improperly joined under Rule 20 because each arose from a separate alleged assault with distinct facts and participants, and it severed the claims into separate actions under Rule 21 despite the complaint’s allegations of a prison-wide pattern of excessive force.


Griggs v. Holt, 2018 WL 5283448 (2018)