Nuuh Na'im v. James Beck

── Nuuh Na'im v. James Beck ── Court: Court of Appeals for the Eighth Circuit Date: April 15, 2026 Category: General United States Court of Appeals For the Eighth Circuit ___________________________ No. 24-2711 ___________________________ Nuuh Amir Na’im, lllllllllllllllllllllPlaintiff - Appellant, v. James Beck, Doctor, Arkansas Department of Corrections/Wellpath (Cummins Unit)(originally names as Beck); Carol Chisom, RN, Director of Nurses, Arkansas Department of Corrections/Wellpath (Cummins Unit)(originally names as C Chisom); Lerizza Nunag, APRN, Arkansas Department of Corrections/Wellpath (Cummins Unit)(originally named as Nunag); Rose Newby, APARN, Arkansas Department of Corrections/Wellpath (Cummins Unit)(originally named as Newby); Shakita Green, CNA, Arkansas Department of Corrections/Wellpath (Cummins Unit)(originally named as Green), lllllllllllllllllllllDefendants - Appellees. ____________ Appeal from United States District Court for the Eastern District of Arkansas - Central ____________ Submitted: November 18, 2025 Filed: April 15, 2026 ____________ Before COLLOTON, Chief Judge, SHEPHERD and ERICKSON, Circuit Judges. ____________ COLLOTON, Chief Judge. Nuuh Amir Na’im, an inmate in Arkansas, sued medical staff from the Arkansas Department of Corrections and alleged violations of the Eighth Amendment. The district court* dismissed some of Na’im’s claims for failure to exhaust administrative remedies, and the court granted summary judgment for the defendants on the remaining claim. We affirm. I. Na’im dislocated his right pinky finger while playing basketball at Cummins Unit, a state prison facility, on May 12, 2021. He visited the prison’s infirmary, and staff placed his hand in a splint and administered Ibuprofen. Medical staff also ordered an x-ray. The next day, Na’im submitted an emergency grievance that said he was still in pain. In response, a nurse at the prison’s infirmary gave Na’im a dose of Ibuprofen and placed him on the “medical lay-in list for an emergency x-ray.” The x-ray revealed that Na’im’s finger was dislocated and had an “abnormal widening of the scapholunate interval,” but there was “no definite fracture.” On May 19, Dr. James Beck and Nurse Lerizza Nunag attempted to realign Na’im’s dislocated finger. They were unsuccessful, so Beck and Nunag provided Na’im with pain medication, gave him a ketorolac injection to manage pain, and placed his finger in a splint. At Beck’s direction, Nunag requested approval for Na’im to see an orthopedic surgeon. Na’im consulted with an orthopedic surgeon on June 14, and the surgeon reset the finger on June 24. * The Honorable Billy Roy Wilson, United States District Judge for the Eastern District of Arkansas, now deceased, adopting the recommended disposition of the Honorable Benecia B. Moore, United States Magistrate Judge for the Eastern District of Arkansas. -2-  During the relevant time period, the Department of Corrections maintained and published an Inmate Grievance Procedure policy for the resolution of inmates’ complaints. At the first step, an inmate submits a written complaint to facilitate potential informal resolution of the matter. The policy directs inmates to “write a brief statement that is specific as to the substance of the issue or complaint to include the date, place, personnel involved or witnesses.” If an inmate is not able to resolve the matter informally, then he may proceed to the second step of filing a formal complaint. The formal complaint must