Cheng v. Grenier

U.S. District Court, District of Minnesota

Cheng v. Grenier

Trial Court Opinion

                 UNITED STATES DISTRICT COURT                            
                    DISTRICT OF MINNESOTA                                

Sheng-Wen Cheng,                  Case No. 23-cv-0485 (WMW/DLM)          
                        Plaintiff,                                       

ORDER

v.                                                                       
P. Grenier and The United States                                         
of America,                                                              
                      Defendants.                                        
    P. Grenier and  the  United  States  of America  (collectively  “Defendants”)  seek
dismissal for lack of subject-matter jurisdiction or for failure to state a claim.1 (Dkt. 46.) 
For the reasons addressed below, the Court grants Defendants’ motion to dismiss. 
                         BACKGROUND                                      
    Plaintiff Sheng-Wen Cheng (“Cheng”) is a federal inmate serving a 72-month 

sentence for fraud against the United States.  Cheng is incarcerated at FMC Rochester and 
commenced this action against P. Grenier  (“Grenier”), a counselor employed by  the 
Federal Bureau of Prisons (“BOP”) at FCI Sandstone, and the United States of America.  
Cheng sues Grenier in his individual capacity and his official capacity.   
    When Cheng commenced this action on March 1, 2023, he was incarcerated at FCI 

Sandstone.  Cheng sought a Temporary Restraining Order/Preliminary Injunction, asking 

1 Alternatively, Defendants move for summary judgment.  Because Defendants failed to 
seek permission to file an early motion for summary judgment following this Court’s 
September 18, 2023 Order, (Dkt. 59), Defendants’ alternative argument to dismiss Cheng’s 
claims under Rule 56 will not be considered.                              
for Grenier to be suspended or terminated.  Cheng was then transferred to FMC Rochester.  
Cheng amended his complaint after the transfer and refiled his motion for injunctive relief.  

This  Court  denied  Cheng’s  motion  for  a  Temporary  Restraining  Order/Preliminary 
Injunction.                                                               
    In Cheng’s amended  complaint, he alleges  that, between November 2022 and 
February 2023, Grenier thwarted his attempts to utilize the administrative process under 
the  Prison  Litigation  Reform  Act  (“PLRA”)  and  limited  his  access  to  the  courts.  
Specifically, among several other allegations, Cheng alleges that Grenier threatened to 

move Cheng to an inferior housing unit if Cheng submitted an informal resolution (“BP-
8”), intentionally told Cheng to “get lost” while Cheng was waiting for his case manager’s 
assistance in making copies of necessary documents, failed to respond to Cheng’s BP-8s, 
failed to provide Cheng with an administrative remedy request form (“BP-9”), provided 
Cheng incorrect forms, and refused to respond to Cheng’s requests that are relevant to 

Cheng’s ongoing lawsuits.                                                 
    Cheng  alleges  in  his  amended  complaint  that  Grenier’s  actions  and  failure  to 
respond to  Cheng’s  requests  violated  Cheng’s First  Amendment  rights  and  his Fifth 
Amendment  right  to  due  process,  causing  Cheng  irreparable  harm.    Cheng  requests 
injunctive relief, specifically for Grenier to be suspended or terminated from his position.2  




2 As Cheng concedes that his request for declaratory judgment and injunctive relief is moot 
after his transfer from FCI Sandstone to FMC Rochester, (Dkt. 63 at 8), this Court will not 
address these claims.                                                     
    Defendants  move  to  dismiss  Cheng’s  complaint  for  lack  of  subject-matter 
jurisdiction, Fed. R. Civ. P. 12(b)(1), and for failure to state a claim, Fed. R. Civ. P. 

12(b)(6).                                                                 
                           ANALYSIS                                      
    Cheng’s complaint includes five claims: two violations of the First Amendment to 
the United States Constitution (retaliation and right to petition); a violation of the Fifth 
Amendment to the United States Constitution (due process); and two torts (negligence and 
misrepresentation).  Defendants move to dismiss the complaint on three bases: the Court 

lacks subject-matter jurisdiction over each of Cheng’s claims, Cheng has failed to state a 
claim, and there are no genuine issues of material fact.  Cheng opposes the motion as to 
each claim.                                                               
    When  subject-matter  jurisdiction  is  challenged,  the  court  can consider  matters 
outside the pleadings.  Osborn v. United States, 
918 F.2d 724, 729
 (8th Cir. 1990).  A 

defendant may challenge a plaintiff’s complaint for lack of subject-matter jurisdiction 
either on the face of the complaint or on the factual truthfulness of the complaint’s 
averments.  See Fed. R. Civ. P. 12(b)(1); Titus v. Sullivan, 
4 F.3d 590, 593
 (8th Cir. 1993).  
In a facial challenge, as presented here, the nonmoving party “receives the same protections 
as it would defending against a motion brought under Rule 12(b)(6).”  Osborn, 
918 F.2d at 729
 n.6.  Under Rule 12(b)(6), a complaint must allege sufficient facts that, when accepted 
as true, state a facially plausible claim to relief.  Ashcroft v. Iqbal, 
556 U.S. 662, 678
 (2009).  
When determining whether the complaint states such a claim, a district court accepts as 
true all factual allegations in the complaint and draws all reasonable inferences in the 
plaintiff’s favor.  Blankenship v. USA Truck, Inc., 
601 F.3d 852, 853
 (8th Cir. 2010). 

 I.   Exhaustion of Administrative Remedies                              
    Defendants contend that Cheng’s claims must be dismissed because he has failed to 
exhaust his administrative remedies.  Cheng maintains that his failure to exhaust should be 
excused because Grenier made the administrative process unavailable to Cheng, despite 
Cheng’s attempts to exhaust his administrative remedies.  Defendants respond that Cheng’s 
argument lacks sufficient evidentiary support.                            

    Before filing a lawsuit objecting to prison conditions, an inmate must exhaust 
administrative remedies.  42 U.S.C § 1997e(a).  The PLRA provides that “[n]o action shall 
be brought with respect to prison conditions under section 1983 of this title, or any other 
Federal law, by a prisoner confined in any jail, prison, or other correctional facility until 
such administrative remedies as are available are exhausted.”  Id.  The PLRA requires 

inmates to exhaust their available administrative remedies fully and properly as to each 
claim in the complaint before filing an action in federal court.  Woodford v. Ngo, 
548 U.S. 81, 93
 (2006); Johnson v. Jones, 
340 F.3d 624
, 627-28 (8th Cir. 2003); see also Muhammad 
v. Mayfield, 
933 F.3d 993, 1000
 (8th Cir. 2019).  The purpose of this requirement is “to 
reduce the quantity and improve the quality of prisoner suits” by giving “corrections 

officials  time  and  opportunity  to  address  complaints  internally  before  allowing  the 
initiation of a federal case.”  Porter v. Nussle, 
534 U.S. 516, 524-25
 (2002).  A case must 
be dismissed when an inmate fails to exhaust available administrative remedies before 
initiating a lawsuit.  Johnson, 340 F.3d at 627; Robley v. Anderson, No. 02-cv-4199 
(JRT/RLE), 
2004 WL 742089
, at *2 (D. Minn. Mar. 4, 2004) (explaining that “[t]he 
PLRA’s exhaustion requirement is mandatory”). In addition, the PLRA requires “proper 

exhaustion.” Woodford, 
548 U.S. at 93
.  “Proper exhaustion demands compliance with an 
agency’s deadlines and other critical procedural rules. . . .”  
Id. at 90
.  The failure to exhaust 
administrative remedies is an affirmative defense that the Defendants must plead and prove.  
Nerness v. Johnson, 
401 F.3d 874, 876
 (8th Cir. 2005).                    
    “For  exhaustion  of  remedies  to  serve  its  purposes,  those  remedies  must  be 
‘available.’”  Spencer v. Warden FPC Duluth, 13-177 JNE/JJK, 
2014 WL 5106741
, at *3 

(D. Minn. Oct. 10, 2014).  Remedies are unavailable if the prison prevents prisoners from 
exhausting.  Miller v. Norris, 
247 F.3d 736, 740
 (8th Cir. 2001).  A prisoner’s subjective 
belief that the procedures are unavailable is insufficient to establish unavailability.  Lyon 
v. Vande Krol, 
305 F.3d 806, 809
 (8th Cir. 2002).  However, the Eighth Circuit, when 
considering a motion to dismiss, found the allegation that a prison official refused to 

respond to a prisoner’s informal resolution (BP-8) raised an inference that administrative 
remedies were made unavailable to the prisoner.  Foulk v. Charrier, 
262 F.3d 687, 698
 (8th 
Cir. 2001).  Additionally, a prisoner’s allegations that he never received his requested 
administrative  grievance  form  may  be  sufficient  to  “raise  an  inference  that  he  was 
prevented from utilizing the prison’s administrative remedies.”  Miller, 
247 F.3d at 740
.   

    To survive Defendants’ motion to dismiss, Cheng must plead sufficient facts to raise 
an  inference  that  the  administrative  process  was  unavailable  to  him  or  that  he  was 
prevented from utilizing the administrative process.                      
    Cheng alleges that Grenier, his counselor, thwarted Cheng’s efforts to exhaust his 
administrative remedies by failing to respond to the BP-8 forms Cheng submitted and by 

refusing to provide Cheng the BP-9 forms he requested.  In his declaration, Cheng supports 
these allegations by swearing that “Grenier was the person with the only authority who 
could provide me with a BP-9 while I was at FCI Sandstone” and “[w]ithout a BP-9 form 
provided by Grenier, I cannot submit any administrative remedy to the Warden of FCI 
Sandstone or other prison employees at FCI Sandstone.”  (Dkt. 64 ¶¶ 7, 8.)  Defendants 

contend that Cheng’s declaration is insufficient proof that Grenier made administrative 
remedies unavailable to Cheng.  Defendants also disagree with Cheng, and through a 
declaration submitted by a BOP paralegal, swear that “any correctional/unit counselor can 
provide the administrative remedy request forms to inmates, and at FCI-Sandstone there 
are several correctional/unit counselors in addition to Defendant P. Grenier.”  (Dkt. 67 ¶ 9.)  

However, according to the BOP Administrative Remedy Program Statement, “ordinarily” 
the correctional counselor provides the inmate the appropriate form.3  (Dkt. 50-4 at 5.) 
    Considering the BOP Administrative Remedy Program Statement and the parties’ 
conflicting declarations, this Court finds that Cheng has pled sufficient facts to raise an 

inference that the administrative process was unavailable to him.  For this reason, the Court 
lacks a factual basis to dismiss for Cheng’s failure to exhaust administrative remedies.   



3 Administrative Remedy Program Statement, U.S. Department of Justice Federal Bureau 
of Prisons, 5 (2014), https://www.bop.gov/policy/progstat/1330_018.pdf.   
 II.  Bivens Claims                                                      
    Cheng urges this Court to recognize his First Amendment and Fifth Amendment 

claims under Bivens v. Six Unknown Named Agents of Fed. Bureau of Narcotics, 
403 U.S. 388
 (1971).  While conceding that his First Amendment and Fifth Amendment claims arise 
in new contexts, Cheng argues that special factors warrant recognizing his claims under 
Bivens.  Defendants disagree, arguing that special factors “counsel hesitation” rather than 
support recognizing Cheng’s claims under Bivens.                          
    The Supreme Court of the United States has recognized a cause of action under 

Bivens  three  times.    Carlson  v.  Green,  
446 U.S. 14
  (1980)  (recognizing  an  Eighth 
Amendment  claim);  Davis  v.  Passman,  
442 U.S. 228
  (1979)  (recognizing  a  Fifth 
Amendment claim for gender discrimination); Bivens, 
403 U.S. 388
 (recognizing a Fourth 
Amendment claim).  Whether an implied cause of action is available under Bivens is a two-
step inquiry.  Farah v. Weyker, 
926 F.3d 492, 498
 (8th Cir. 2019).  First, the court 

determines whether Cheng’s claims present one of “the three Bivens claims the Court has 
[found] in the past,” or whether Cheng’s claims arise in a “new context.”  Ziglar v. Abbasi, 
582 U.S. 120, 140
 (2017).  If Cheng’s claims arise in a new context, the Court proceeds to 
Step two, which requires the court to determine whether “any special factors counsel 
hesitation before implying a new cause of action.”  Farah, 
926 F.3d at 498
 (internal 

quotation marks omitted).  If there are reasons to pause, and as the Eighth Circuit noted in 
Farah, “[i]t does not take much to make [the Court] pause,” the Court must refuse to find 
an implied cause of action.  
Id. at 500-01
.  Special factors to consider include economic 
and governmental concerns, such as: “(1) the cost of defending claims against federal 
officials; (2) the responsibility of Congress to determine whether monetary and other 
liabilities should be imposed upon federal actors; and (3) the time, administrative costs, 

and other resources used during a lengthy period of litigation.”  Pinson v. Hadaway, 
2020 WL 6121357
, at *8 (citing Abbasi, 
582 U.S. at 133-34
).  Additional special factors to 
consider include Congress’s actions, specifically, “whether Congress has taken other action 
in the area without authorizing a damages remedy, and whether a ‘remedial structure’ is 
already in place to address constitutional violations.”  Farah, 
926 F.3d at 500
 (quoting 
Abbasi, 
582 U.S. at 141
) (internal citations omitted).  “[I]f Congress has created ‘any 

alternative, existing process for protecting the [injured party’s] interest’ that itself may 
‘amoun[t] to a convincing reason for the Judicial Branch to refrain from providing a new 
and freestanding remedy in damages.’” Abbasi, 
582 U.S. at 137
 (quoting Wilkie v. Robbins, 
551 U.S. 537, 550
 (2007)).                                                
    Cheng concedes that his claims arise in new contexts.  This Court, therefore, 

proceeds to Step two.  The economic and governmental concerns favor not finding an 
implied cause of action under Bivens.  In these contexts, the extension of Bivens risks 
“burdening and interfering with the executive branch’s investigative and prosecutorial 
functions.”  Farah, 
926 F.3d at 500
.  Recognizing such claims in these contexts also would 
likely  exponentially  increase  litigation  against  BOP  officials,  further  increasing  the 

resources consumed during a lengthy period of litigation.                 
    The special factors regarding Congress’s actions also weigh against finding an 
implied cause of action under Bivens.  Congress passed the PLRA which requires inmates 
to exhaust their administrative remedies prior to filing a civil rights lawsuit, allowing 
inmates to seek redress through the BOP hierarchy.  42 U.S.C. § 1997e(a).  Although the 
administrative remedy process does not authorize a damages remedy, it does provide 

inmates an avenue for redress for “allegedly unconstitutional actions and policies.”  Corr. 
Servs. Corp. v. Malesko, 
534 U.S. 61, 74
 (2001).  The Federal Torts Claims Act (“FTCA”) 
provides an additional remedial structure for an inmate’s grievances.  The FTCA allows 
individuals injured by the negligent acts or omissions of federal employees acting within 
the scope of their employment to recover for their injuries by bringing a claim against the 
United States.  
28 U.S.C. § 2679
(b)(1); Hinsley v. Standing Rock Child Protective Servs., 

516 F.3d 668, 671-72
 (8th Cir. 2008) (citing 
28 U.S.C. § 1346
(b)).  Although Cheng is 
correct that an inmate cannot recover for intentional acts or omission of a federal employee 
under the FTCA, and that actions under the FTCA can be brought only against the official 
in their official capacity, not individual capacity, the FTCA still provides a “remedial 
structure” to address constitutional violations.  That these remedies do not provide the same 

form of relief as a Bivens action is immaterial.  See Malesko, 
534 U.S. at 69
 (“So long as 
the plaintiff had an avenue for some redress, bedrock principles of separation of powers 
foreclosed judicial imposition of a new substantive liability.”); Farah, 
926 F.3d at 502
 
(noting that the Supreme Court “has since made clear that even remedies that provide no 
compensation for victims and little deterrence for violators . . . trigger the general rule that 

‘when alternative methods of relief are available, a Bivens remedy usually is not.’”) 
(quoting Abbasi, 
582 U.S. at 145
).                                        
    Because Congress is best suited to weigh the costs and benefits of creating a new 
substantive legal liability, and the special factors weigh in favor of not finding an implied 
cause of action under Bivens, the Court dismisses Cheng’s claims against Grenier in his 
individual capacity.                                                      

 III.  Federal Tort Claims Act Claims                                    
    Cheng  raises  two  claims  under  the  FTCA:  negligence  and  misrepresentation.  
Defendants argue that Cheng’s negligence claim must be dismissed because Cheng failed 
to  exhaust  his  administrative  remedies  as  required  under  the  FTCA,  and  Cheng’s 
misrepresentation claim must be dismissed because it is not cognizable under the FTCA.  
Cheng does not rebut Defendant’s argument regarding his misrepresentation claim.  But 

Cheng argues that he did exhaust his administrative remedies as required by the FTCA for 
his negligence claim.                                                     
    The United States and its agencies are immune from suit unless the United States 
waives its sovereign immunity.  Fed. Deposit Ins. Corp. v. Meyer, 
510 U.S. 471, 475
 (1994).  
If the United States does not waive sovereign immunity, a federal court does not have 

subject-matter jurisdiction over the claims brought against the United States.  
Id.
  The 
FTCA provides a limited waiver of the United States’s sovereign immunity, allowing 
persons injured by federal employees to sue the United States for damages in federal court.  
Mader v. United States, 
654 F.3d 794, 797
 (8th Cir. 2011).  Specifically, the FTCA allows 
lawsuits for “‘injury or loss of property or personal injury or death caused by the negligent 

or  wrongful  act  or  omission’  of  federal  employees  acting  within  the  scope  of  their 
employment.”  
28 U.S.C. § 2675
(a).  It does not allow lawsuits for claims arising out of 
misrepresentation. See 
28 U.S.C. § 2680
(h).                               
    To  bring  a  lawsuit  under  the  FTCA,  the  claimants  must  first  exhaust  their 
administrative remedies.  Mader, 
654 F.3d at 797
; 
28 U.S.C. § 2675
(a). The exhaustion 

requirement requires “complete exhaustion,” meaning the claim has “been finally denied 
by the agency in writing and sent to the claimant by certified or registered mail” before the 
claimant files a lawsuit in federal court.  
28 U.S.C. § 2675
(a).  Or if the agency fails “to 
make a final disposition within six months” after the claimant’s filing, the grievance may 
be considered denied and the FTCA’s administrative remedies exhausted.  
Id.
  Exhaustion 
is not complete if the lawsuit is initiated before the grievance has been denied or the six-

month period has elapsed.  Id.; Johnson v. U.S. Dep’t of Def., No. 99-cv-1699 (DWF/AJB), 
2000 WL 33956225
, at *2 (D. Minn. Oct. 17, 2000).  The filing date of the original 
complaint is the operative date for exhaustion, not the date of an amended complaint.   
Askar v. Hennepin Cnty., 
600 F. Supp. 3d 948
, 955-56 (D. Minn. 2022).     
    The Court does not have subject-matter jurisdiction over either of Cheng’s tort 

claims.  Subject-matter jurisdiction is absent for Cheng’s misrepresentation claim because 
the claim is not cognizable under the FTCA, as the FTCA does not allow lawsuits for 
claims arising out of misrepresentation.  
28 U.S.C. § 2680
(h).            
    The Court similarly lacks jurisdiction over Cheng’s negligence claim because he 
has failed to exhaust his administrative remedies as is required under the FTCA.  Cheng 

filed this lawsuit on March 1, 2023 and filed his tort grievance with FCI Sandstone on May 
8, 2023.  As of Cheng’s surreply filing on December 5, 2023, the BOP (the relevant agency) 
has not denied in writing his tort grievance.  And even though Cheng’s tort grievance is 
now considered “denied” as the BOP has failed “to make a final disposition within six 
months,” Cheng filed this lawsuit prematurely.  Johnson, 
2000 WL 33956225
, at *2.   

    Therefore, because this Court lacks subject-matter jurisdiction over Cheng’s tort 
claims, they are dismissed.                                               
                         CONCLUSION                                      
    Cheng has failed to plead sufficient facts to state a claim under Bivens, and the Court 
lacks subject-matter jurisdiction over his tort claims.  Defendants’ motion to dismiss, 
therefore, is granted.                                                    

ORDER

    Based on the foregoing analysis and all the files, records and proceedings herein, IT 
IS HEREBY ORDERED:                                                        
    1.   Defendants’ motion to dismiss, (Dkt. 46), is GRANTED.           
    2.   Cheng’s claims one, two and three are DISMISSED WITH PREJUDICE. 

    3.   Cheng’s claims four and five are DISMISSED WITHOUT PREJUDICE.   
    LET JUDGMENT BE ENTERED ACCORDIGNLY.                                 

Dated:  January 16, 2024                 s/ Wilhelmina M. Wright         
                                         Wilhelmina M. Wright            
                                         United States District Judge    

Trial Court Opinion

                 UNITED STATES DISTRICT COURT                            
                    DISTRICT OF MINNESOTA                                

Sheng-Wen Cheng,                  Case No. 23-cv-0485 (WMW/DLM)          
                        Plaintiff,                                       

ORDER

v.                                                                       
P. Grenier and The United States                                         
of America,                                                              
                      Defendants.                                        
    P. Grenier and  the  United  States  of America  (collectively  “Defendants”)  seek
dismissal for lack of subject-matter jurisdiction or for failure to state a claim.1 (Dkt. 46.) 
For the reasons addressed below, the Court grants Defendants’ motion to dismiss. 
                         BACKGROUND                                      
    Plaintiff Sheng-Wen Cheng (“Cheng”) is a federal inmate serving a 72-month 

sentence for fraud against the United States.  Cheng is incarcerated at FMC Rochester and 
commenced this action against P. Grenier  (“Grenier”), a counselor employed by  the 
Federal Bureau of Prisons (“BOP”) at FCI Sandstone, and the United States of America.  
Cheng sues Grenier in his individual capacity and his official capacity.   
    When Cheng commenced this action on March 1, 2023, he was incarcerated at FCI 

Sandstone.  Cheng sought a Temporary Restraining Order/Preliminary Injunction, asking 

1 Alternatively, Defendants move for summary judgment.  Because Defendants failed to 
seek permission to file an early motion for summary judgment following this Court’s 
September 18, 2023 Order, (Dkt. 59), Defendants’ alternative argument to dismiss Cheng’s 
claims under Rule 56 will not be considered.                              
for Grenier to be suspended or terminated.  Cheng was then transferred to FMC Rochester.  
Cheng amended his complaint after the transfer and refiled his motion for injunctive relief.  

This  Court  denied  Cheng’s  motion  for  a  Temporary  Restraining  Order/Preliminary 
Injunction.                                                               
    In Cheng’s amended  complaint, he alleges  that, between November 2022 and 
February 2023, Grenier thwarted his attempts to utilize the administrative process under 
the  Prison  Litigation  Reform  Act  (“PLRA”)  and  limited  his  access  to  the  courts.  
Specifically, among several other allegations, Cheng alleges that Grenier threatened to 

move Cheng to an inferior housing unit if Cheng submitted an informal resolution (“BP-
8”), intentionally told Cheng to “get lost” while Cheng was waiting for his case manager’s 
assistance in making copies of necessary documents, failed to respond to Cheng’s BP-8s, 
failed to provide Cheng with an administrative remedy request form (“BP-9”), provided 
Cheng incorrect forms, and refused to respond to Cheng’s requests that are relevant to 

Cheng’s ongoing lawsuits.                                                 
    Cheng  alleges  in  his  amended  complaint  that  Grenier’s  actions  and  failure  to 
respond to  Cheng’s  requests  violated  Cheng’s First  Amendment  rights  and  his Fifth 
Amendment  right  to  due  process,  causing  Cheng  irreparable  harm.    Cheng  requests 
injunctive relief, specifically for Grenier to be suspended or terminated from his position.2  




2 As Cheng concedes that his request for declaratory judgment and injunctive relief is moot 
after his transfer from FCI Sandstone to FMC Rochester, (Dkt. 63 at 8), this Court will not 
address these claims.                                                     
    Defendants  move  to  dismiss  Cheng’s  complaint  for  lack  of  subject-matter 
jurisdiction, Fed. R. Civ. P. 12(b)(1), and for failure to state a claim, Fed. R. Civ. P. 

12(b)(6).                                                                 
                           ANALYSIS                                      
    Cheng’s complaint includes five claims: two violations of the First Amendment to 
the United States Constitution (retaliation and right to petition); a violation of the Fifth 
Amendment to the United States Constitution (due process); and two torts (negligence and 
misrepresentation).  Defendants move to dismiss the complaint on three bases: the Court 

lacks subject-matter jurisdiction over each of Cheng’s claims, Cheng has failed to state a 
claim, and there are no genuine issues of material fact.  Cheng opposes the motion as to 
each claim.                                                               
    When  subject-matter  jurisdiction  is  challenged,  the  court  can consider  matters 
outside the pleadings.  Osborn v. United States, 
918 F.2d 724, 729
 (8th Cir. 1990).  A 

defendant may challenge a plaintiff’s complaint for lack of subject-matter jurisdiction 
either on the face of the complaint or on the factual truthfulness of the complaint’s 
averments.  See Fed. R. Civ. P. 12(b)(1); Titus v. Sullivan, 
4 F.3d 590, 593
 (8th Cir. 1993).  
In a facial challenge, as presented here, the nonmoving party “receives the same protections 
as it would defending against a motion brought under Rule 12(b)(6).”  Osborn, 
918 F.2d at 729
 n.6.  Under Rule 12(b)(6), a complaint must allege sufficient facts that, when accepted 
as true, state a facially plausible claim to relief.  Ashcroft v. Iqbal, 
556 U.S. 662, 678
 (2009).  
When determining whether the complaint states such a claim, a district court accepts as 
true all factual allegations in the complaint and draws all reasonable inferences in the 
plaintiff’s favor.  Blankenship v. USA Truck, Inc., 
601 F.3d 852, 853
 (8th Cir. 2010). 

 I.   Exhaustion of Administrative Remedies                              
    Defendants contend that Cheng’s claims must be dismissed because he has failed to 
exhaust his administrative remedies.  Cheng maintains that his failure to exhaust should be 
excused because Grenier made the administrative process unavailable to Cheng, despite 
Cheng’s attempts to exhaust his administrative remedies.  Defendants respond that Cheng’s 
argument lacks sufficient evidentiary support.                            

    Before filing a lawsuit objecting to prison conditions, an inmate must exhaust 
administrative remedies.  42 U.S.C § 1997e(a).  The PLRA provides that “[n]o action shall 
be brought with respect to prison conditions under section 1983 of this title, or any other 
Federal law, by a prisoner confined in any jail, prison, or other correctional facility until 
such administrative remedies as are available are exhausted.”  Id.  The PLRA requires 

inmates to exhaust their available administrative remedies fully and properly as to each 
claim in the complaint before filing an action in federal court.  Woodford v. Ngo, 
548 U.S. 81, 93
 (2006); Johnson v. Jones, 
340 F.3d 624
, 627-28 (8th Cir. 2003); see also Muhammad 
v. Mayfield, 
933 F.3d 993, 1000
 (8th Cir. 2019).  The purpose of this requirement is “to 
reduce the quantity and improve the quality of prisoner suits” by giving “corrections 

officials  time  and  opportunity  to  address  complaints  internally  before  allowing  the 
initiation of a federal case.”  Porter v. Nussle, 
534 U.S. 516, 524-25
 (2002).  A case must 
be dismissed when an inmate fails to exhaust available administrative remedies before 
initiating a lawsuit.  Johnson, 340 F.3d at 627; Robley v. Anderson, No. 02-cv-4199 
(JRT/RLE), 
2004 WL 742089
, at *2 (D. Minn. Mar. 4, 2004) (explaining that “[t]he 
PLRA’s exhaustion requirement is mandatory”). In addition, the PLRA requires “proper 

exhaustion.” Woodford, 
548 U.S. at 93
.  “Proper exhaustion demands compliance with an 
agency’s deadlines and other critical procedural rules. . . .”  
Id. at 90
.  The failure to exhaust 
administrative remedies is an affirmative defense that the Defendants must plead and prove.  
Nerness v. Johnson, 
401 F.3d 874, 876
 (8th Cir. 2005).                    
    “For  exhaustion  of  remedies  to  serve  its  purposes,  those  remedies  must  be 
‘available.’”  Spencer v. Warden FPC Duluth, 13-177 JNE/JJK, 
2014 WL 5106741
, at *3 

(D. Minn. Oct. 10, 2014).  Remedies are unavailable if the prison prevents prisoners from 
exhausting.  Miller v. Norris, 
247 F.3d 736, 740
 (8th Cir. 2001).  A prisoner’s subjective 
belief that the procedures are unavailable is insufficient to establish unavailability.  Lyon 
v. Vande Krol, 
305 F.3d 806, 809
 (8th Cir. 2002).  However, the Eighth Circuit, when 
considering a motion to dismiss, found the allegation that a prison official refused to 

respond to a prisoner’s informal resolution (BP-8) raised an inference that administrative 
remedies were made unavailable to the prisoner.  Foulk v. Charrier, 
262 F.3d 687, 698
 (8th 
Cir. 2001).  Additionally, a prisoner’s allegations that he never received his requested 
administrative  grievance  form  may  be  sufficient  to  “raise  an  inference  that  he  was 
prevented from utilizing the prison’s administrative remedies.”  Miller, 
247 F.3d at 740
.   

    To survive Defendants’ motion to dismiss, Cheng must plead sufficient facts to raise 
an  inference  that  the  administrative  process  was  unavailable  to  him  or  that  he  was 
prevented from utilizing the administrative process.                      
    Cheng alleges that Grenier, his counselor, thwarted Cheng’s efforts to exhaust his 
administrative remedies by failing to respond to the BP-8 forms Cheng submitted and by 

refusing to provide Cheng the BP-9 forms he requested.  In his declaration, Cheng supports 
these allegations by swearing that “Grenier was the person with the only authority who 
could provide me with a BP-9 while I was at FCI Sandstone” and “[w]ithout a BP-9 form 
provided by Grenier, I cannot submit any administrative remedy to the Warden of FCI 
Sandstone or other prison employees at FCI Sandstone.”  (Dkt. 64 ¶¶ 7, 8.)  Defendants 

contend that Cheng’s declaration is insufficient proof that Grenier made administrative 
remedies unavailable to Cheng.  Defendants also disagree with Cheng, and through a 
declaration submitted by a BOP paralegal, swear that “any correctional/unit counselor can 
provide the administrative remedy request forms to inmates, and at FCI-Sandstone there 
are several correctional/unit counselors in addition to Defendant P. Grenier.”  (Dkt. 67 ¶ 9.)  

However, according to the BOP Administrative Remedy Program Statement, “ordinarily” 
the correctional counselor provides the inmate the appropriate form.3  (Dkt. 50-4 at 5.) 
    Considering the BOP Administrative Remedy Program Statement and the parties’ 
conflicting declarations, this Court finds that Cheng has pled sufficient facts to raise an 

inference that the administrative process was unavailable to him.  For this reason, the Court 
lacks a factual basis to dismiss for Cheng’s failure to exhaust administrative remedies.   



3 Administrative Remedy Program Statement, U.S. Department of Justice Federal Bureau 
of Prisons, 5 (2014), https://www.bop.gov/policy/progstat/1330_018.pdf.   
 II.  Bivens Claims                                                      
    Cheng urges this Court to recognize his First Amendment and Fifth Amendment 

claims under Bivens v. Six Unknown Named Agents of Fed. Bureau of Narcotics, 
403 U.S. 388
 (1971).  While conceding that his First Amendment and Fifth Amendment claims arise 
in new contexts, Cheng argues that special factors warrant recognizing his claims under 
Bivens.  Defendants disagree, arguing that special factors “counsel hesitation” rather than 
support recognizing Cheng’s claims under Bivens.                          
    The Supreme Court of the United States has recognized a cause of action under 

Bivens  three  times.    Carlson  v.  Green,  
446 U.S. 14
  (1980)  (recognizing  an  Eighth 
Amendment  claim);  Davis  v.  Passman,  
442 U.S. 228
  (1979)  (recognizing  a  Fifth 
Amendment claim for gender discrimination); Bivens, 
403 U.S. 388
 (recognizing a Fourth 
Amendment claim).  Whether an implied cause of action is available under Bivens is a two-
step inquiry.  Farah v. Weyker, 
926 F.3d 492, 498
 (8th Cir. 2019).  First, the court 

determines whether Cheng’s claims present one of “the three Bivens claims the Court has 
[found] in the past,” or whether Cheng’s claims arise in a “new context.”  Ziglar v. Abbasi, 
582 U.S. 120, 140
 (2017).  If Cheng’s claims arise in a new context, the Court proceeds to 
Step two, which requires the court to determine whether “any special factors counsel 
hesitation before implying a new cause of action.”  Farah, 
926 F.3d at 498
 (internal 

quotation marks omitted).  If there are reasons to pause, and as the Eighth Circuit noted in 
Farah, “[i]t does not take much to make [the Court] pause,” the Court must refuse to find 
an implied cause of action.  
Id. at 500-01
.  Special factors to consider include economic 
and governmental concerns, such as: “(1) the cost of defending claims against federal 
officials; (2) the responsibility of Congress to determine whether monetary and other 
liabilities should be imposed upon federal actors; and (3) the time, administrative costs, 

and other resources used during a lengthy period of litigation.”  Pinson v. Hadaway, 
2020 WL 6121357
, at *8 (citing Abbasi, 
582 U.S. at 133-34
).  Additional special factors to 
consider include Congress’s actions, specifically, “whether Congress has taken other action 
in the area without authorizing a damages remedy, and whether a ‘remedial structure’ is 
already in place to address constitutional violations.”  Farah, 
926 F.3d at 500
 (quoting 
Abbasi, 
582 U.S. at 141
) (internal citations omitted).  “[I]f Congress has created ‘any 

alternative, existing process for protecting the [injured party’s] interest’ that itself may 
‘amoun[t] to a convincing reason for the Judicial Branch to refrain from providing a new 
and freestanding remedy in damages.’” Abbasi, 
582 U.S. at 137
 (quoting Wilkie v. Robbins, 
551 U.S. 537, 550
 (2007)).                                                
    Cheng concedes that his claims arise in new contexts.  This Court, therefore, 

proceeds to Step two.  The economic and governmental concerns favor not finding an 
implied cause of action under Bivens.  In these contexts, the extension of Bivens risks 
“burdening and interfering with the executive branch’s investigative and prosecutorial 
functions.”  Farah, 
926 F.3d at 500
.  Recognizing such claims in these contexts also would 
likely  exponentially  increase  litigation  against  BOP  officials,  further  increasing  the 

resources consumed during a lengthy period of litigation.                 
    The special factors regarding Congress’s actions also weigh against finding an 
implied cause of action under Bivens.  Congress passed the PLRA which requires inmates 
to exhaust their administrative remedies prior to filing a civil rights lawsuit, allowing 
inmates to seek redress through the BOP hierarchy.  42 U.S.C. § 1997e(a).  Although the 
administrative remedy process does not authorize a damages remedy, it does provide 

inmates an avenue for redress for “allegedly unconstitutional actions and policies.”  Corr. 
Servs. Corp. v. Malesko, 
534 U.S. 61, 74
 (2001).  The Federal Torts Claims Act (“FTCA”) 
provides an additional remedial structure for an inmate’s grievances.  The FTCA allows 
individuals injured by the negligent acts or omissions of federal employees acting within 
the scope of their employment to recover for their injuries by bringing a claim against the 
United States.  
28 U.S.C. § 2679
(b)(1); Hinsley v. Standing Rock Child Protective Servs., 

516 F.3d 668, 671-72
 (8th Cir. 2008) (citing 
28 U.S.C. § 1346
(b)).  Although Cheng is 
correct that an inmate cannot recover for intentional acts or omission of a federal employee 
under the FTCA, and that actions under the FTCA can be brought only against the official 
in their official capacity, not individual capacity, the FTCA still provides a “remedial 
structure” to address constitutional violations.  That these remedies do not provide the same 

form of relief as a Bivens action is immaterial.  See Malesko, 
534 U.S. at 69
 (“So long as 
the plaintiff had an avenue for some redress, bedrock principles of separation of powers 
foreclosed judicial imposition of a new substantive liability.”); Farah, 
926 F.3d at 502
 
(noting that the Supreme Court “has since made clear that even remedies that provide no 
compensation for victims and little deterrence for violators . . . trigger the general rule that 

‘when alternative methods of relief are available, a Bivens remedy usually is not.’”) 
(quoting Abbasi, 
582 U.S. at 145
).                                        
    Because Congress is best suited to weigh the costs and benefits of creating a new 
substantive legal liability, and the special factors weigh in favor of not finding an implied 
cause of action under Bivens, the Court dismisses Cheng’s claims against Grenier in his 
individual capacity.                                                      

 III.  Federal Tort Claims Act Claims                                    
    Cheng  raises  two  claims  under  the  FTCA:  negligence  and  misrepresentation.  
Defendants argue that Cheng’s negligence claim must be dismissed because Cheng failed 
to  exhaust  his  administrative  remedies  as  required  under  the  FTCA,  and  Cheng’s 
misrepresentation claim must be dismissed because it is not cognizable under the FTCA.  
Cheng does not rebut Defendant’s argument regarding his misrepresentation claim.  But 

Cheng argues that he did exhaust his administrative remedies as required by the FTCA for 
his negligence claim.                                                     
    The United States and its agencies are immune from suit unless the United States 
waives its sovereign immunity.  Fed. Deposit Ins. Corp. v. Meyer, 
510 U.S. 471, 475
 (1994).  
If the United States does not waive sovereign immunity, a federal court does not have 

subject-matter jurisdiction over the claims brought against the United States.  
Id.
  The 
FTCA provides a limited waiver of the United States’s sovereign immunity, allowing 
persons injured by federal employees to sue the United States for damages in federal court.  
Mader v. United States, 
654 F.3d 794, 797
 (8th Cir. 2011).  Specifically, the FTCA allows 
lawsuits for “‘injury or loss of property or personal injury or death caused by the negligent 

or  wrongful  act  or  omission’  of  federal  employees  acting  within  the  scope  of  their 
employment.”  
28 U.S.C. § 2675
(a).  It does not allow lawsuits for claims arising out of 
misrepresentation. See 
28 U.S.C. § 2680
(h).                               
    To  bring  a  lawsuit  under  the  FTCA,  the  claimants  must  first  exhaust  their 
administrative remedies.  Mader, 
654 F.3d at 797
; 
28 U.S.C. § 2675
(a). The exhaustion 

requirement requires “complete exhaustion,” meaning the claim has “been finally denied 
by the agency in writing and sent to the claimant by certified or registered mail” before the 
claimant files a lawsuit in federal court.  
28 U.S.C. § 2675
(a).  Or if the agency fails “to 
make a final disposition within six months” after the claimant’s filing, the grievance may 
be considered denied and the FTCA’s administrative remedies exhausted.  
Id.
  Exhaustion 
is not complete if the lawsuit is initiated before the grievance has been denied or the six-

month period has elapsed.  Id.; Johnson v. U.S. Dep’t of Def., No. 99-cv-1699 (DWF/AJB), 
2000 WL 33956225
, at *2 (D. Minn. Oct. 17, 2000).  The filing date of the original 
complaint is the operative date for exhaustion, not the date of an amended complaint.   
Askar v. Hennepin Cnty., 
600 F. Supp. 3d 948
, 955-56 (D. Minn. 2022).     
    The Court does not have subject-matter jurisdiction over either of Cheng’s tort 

claims.  Subject-matter jurisdiction is absent for Cheng’s misrepresentation claim because 
the claim is not cognizable under the FTCA, as the FTCA does not allow lawsuits for 
claims arising out of misrepresentation.  
28 U.S.C. § 2680
(h).            
    The Court similarly lacks jurisdiction over Cheng’s negligence claim because he 
has failed to exhaust his administrative remedies as is required under the FTCA.  Cheng 

filed this lawsuit on March 1, 2023 and filed his tort grievance with FCI Sandstone on May 
8, 2023.  As of Cheng’s surreply filing on December 5, 2023, the BOP (the relevant agency) 
has not denied in writing his tort grievance.  And even though Cheng’s tort grievance is 
now considered “denied” as the BOP has failed “to make a final disposition within six 
months,” Cheng filed this lawsuit prematurely.  Johnson, 
2000 WL 33956225
, at *2.   

    Therefore, because this Court lacks subject-matter jurisdiction over Cheng’s tort 
claims, they are dismissed.                                               
                         CONCLUSION                                      
    Cheng has failed to plead sufficient facts to state a claim under Bivens, and the Court 
lacks subject-matter jurisdiction over his tort claims.  Defendants’ motion to dismiss, 
therefore, is granted.                                                    

ORDER

    Based on the foregoing analysis and all the files, records and proceedings herein, IT 
IS HEREBY ORDERED:                                                        
    1.   Defendants’ motion to dismiss, (Dkt. 46), is GRANTED.           
    2.   Cheng’s claims one, two and three are DISMISSED WITH PREJUDICE. 

    3.   Cheng’s claims four and five are DISMISSED WITHOUT PREJUDICE.   
    LET JUDGMENT BE ENTERED ACCORDIGNLY.                                 

Dated:  January 16, 2024                 s/ Wilhelmina M. Wright         
                                         Wilhelmina M. Wright            
                                         United States District Judge    

Reference

Status
Unknown