Kentrell Welch v. Gavin Liggett
Opinion
Opinion
discussion with staff or submitting an inmate request form.” AR 740.08(1). If the
inmate’s complaint is not resolved through the alternative means, the inmate initiates
2 a three-step process for escalating the grievance. See AR 740.08–740.10. The
inmate’s first step in this process (the second step overall) is to file an informal
grievance. AR 740.08. If the informal grievance is denied, the inmate may escalate
the complaint to a formal grievance, and if that is also denied, the inmate may
escalate the complaint to a second-level formal grievance. AR 740.08, 740.09.
Welch was clearly aware of how these procedures worked. From 2014 to 2021,
Welch filed 189 grievances through the processes outlined in AR 740. Welch won
five outright and prevailed in part on three.
Welch argues AR 740 is “so opaque that it becomes, practically speaking,
incapable of use.” Ross v. Blake, 578 U.S. 632, 643 (2016). But administrative
procedures “need not be sufficiently ‘plain’ as to preclude any reasonable mistake
or debate with respect to their meaning.” Id. at 644. The administrative remedies
“need not meet federal standards, nor must they be plain, speedy, and effective.”