Lawrence Burns v. Sterling Polk

Summary

The court held that summary judgment on exhaustion grounds was improper because Burns's sworn declaration created a genuine dispute over whether the jail's grievance-appeal process was actually available to him. The handbook established an appeal procedure on paper but did not conclusively establish that Burns could use it in practice, and the district court improperly inferred that he misunderstood the process without resolving the factual dispute. The court vacated the judgment and remanded for the district court to determine whether the exhaustion issue should be resolved by a jury or in a preliminary evidentiary hearing.