After Wayne County Jail Deputy Jonith Watt kicked six-month pregnant Jaquetta Coopwood in the stomach and she eventually lost her child after the assault, the district court denied Ms. Coopwood the ability to hold Deputy Watt accountable, ruling that, based on the Prison Litigation Reform Act (PLRA), she did not “properly” exhaust the jail’s grievance process. The MacArthur Justice Center is fighting alongside prisoners with mental illness, like Ms. Coopwood, who are unfairly held responsible for a grievance process made impassable by their untreated and debilitating psychological condition.
On her second day in custody at the Wayne County Jail in Michigan, Ms. Coopwood, who was six months pregnant at the time, asked Deputy Watt for assistance to make a call to her sister. Without provocation, the deputy dragged Ms. Coopwood back into her cell and kicked her in the stomach. Over the next few months, Ms. Coopwood was hospitalized several times because of severe abdominal pain and bleeding; eventually she had a miscarriage.
Ms. Coopwood attempted to seek redress through the jail’s grievance process following the assault. However, Ms. Coopwood – who had nine years’ worth of documented history with mental illness including several bipolar disorder and schizophrenia – was unable to navigate the grievance process due to her struggles with psychosis, hallucinations, delusions, depression, and impaired cognitive functions. To make matters worse, Ms. Coopwood was not given a Jail’s handbook – which included the grievance forms – and was denied help when she asked to speak to “whoever was in charge” about her assault.
Despite her deteriorating mental health, physical pain, and the jail’s unwillingness to assist her, Ms. Coopwood persisted and eventually filled out a grievance form and handed it to a guard. Wayne County’s jail officials, however, failed to file the form or notify Ms. Coopwood about whether it was rejected and on what grounds. Frustrated with the jail’s grievance process, Ms. Coopwood filed an action in federal court.
But the district court ruled against Ms. Coopwood on the basis that she failed to exhaust available “administrative remedies,” holding that the PLRA does not have “an overarching mental capacity exception [which] would permit a prisoner with the slightest impairment to bypass the grievance process in its entirety.” This is incorrect. According to the U.S. Supreme Court, the PLRA has a limitation on the exhaustion rule, requiring district courts to examine whether administrative remedies are “available” to prisoners in light of their particular situation.
The MacArthur Justice Center is representing Ms. Coopwood in the U.S. Court of Appeals for the Sixth Circuit, asserting that the administrative remedies were not available to Ms. Coopwood because her documented mental illness largely incapacitated her, and the jail’s refusal to assist her by providing the grievance forms and pertinent information further hindered her. Either of these is sufficient on its own to render remedies unavailable.
Led by the ACLU, a coalition of organizations dedicated to the rights of incarcerated individuals, filed an amicus brief in support of Ms. Coopwood’s claim, stressing the considerable barriers to exhaustion, particularly for those with mental impairments. Moreover, a group of professors and practitioners of psychiatry and psychology filed an amicus brief explaining the psychological and physiological effects of imprisonment, the mental capacity of individuals in penal confinement, and how remedies can be unavailable to incarcerated individuals with mental illness.
UPDATE
The Sixth Circuit ruled that the district court erroneously applied the PLRA because the jail officials did not provide Ms. Coopwood the grievance.
The Sixth Circuit ruled in favor of Ms. Coopwood’s appeal, recognizing that the district court erroneously applied PLRA since the jail officials did not provide Ms. Coopwood the proper forms to file a grievance. Ms. Coopwood is now able to move forward with her claims against Wayne County