20 Ill. Admin. Code § 504.810
Administrative disciplinary rules: the cases that interpreted this section
22 citing cases reviewed of 24 in the citation index: 15 interpreted the section (annotated below), 7 cited it only in passing. Cases filed after 2025-11-14 may not have been reviewed yet.
Have a situation under 20 Ill. Admin. Code § 504.810?
These notes show how courts have ruled. Ask about your specific facts and see which of these rulings apply, with citations you can check.
Scope of inmate grievances
Section 504.810(a) permits grievances about incidents, problems, or complaints but excludes complaints about decisions outside the Department’s authority, including decisions rendered by the Director; the court found the provision unclear as to whether Tamms transfers could be grieved.
Robert Westefer, Mark Vonperbandt, Allejandro Villazana v. Donald Snyder, Odie Washington, Michael v. Neal · filed 2005-09-06(a)
In Illinois, “incidents, problems, or complaints” may be grieved, Ill. Admin. Code tit. 20, § 504.810(a), but the grievance process cannot be “utilized for complaints regarding decisions that are outside the authority of the Department, such as parole decisions, clemency, or orders regarding length of sentence or decisions that have been rendered by the Director.” ... There seems to be significant confusion within IDOC, presumably caused by the “or decisions that have been rendered by the Director” clause of section 504.810(a), as to whether a Tamms prisoner may grieve his transfer, IDOC did not challenge every plaintiff on exhaustion grounds, and treatment of grievances by IDOC’s ultimate grievance appeal body, the Administrative Review Board (“ARB”), varied among the prisoners. ... But, as this case comes to us, we find the record “hopelessly unclear ... whether any administrative remedy” remained open for the prisoners to challenge their transfers through the grievance process.Read the full opinion on CourtListener →
Grievance content requirements
Section 504.810 requires a formal prison grievance to provide actual details about each aspect of the complaint, including what happened, when and where it happened, and the identity of each person involved.
Boyd v. Pfister · filed 2020-10-30
Defendants don’t challenge the process by which Boyd pursued his grievances. That is, they don’t argue that he skipped a step. Instead, they challenge the content of the grievances. Therefore, the only portion of Illinois law relevant here is the section about the necessary content for a grievance. That section requires formal grievances to contain “actual details regarding each aspect of the offender’s complaint, including what happened, when, where and the name of each person who is the subject of or who is otherwise involved in the complaint.” See Ill. Admin. Code tit. 20, § 504.810.Read the full opinion on CourtListener →
Section 504.810(c) requires a prison grievance to provide factual details about the complaint, including what happened, when, where, and who was involved; if names are unknown, the grievant must provide as much descriptive information as possible.
Morgan v. Wexford Health Source, Inc. · filed 2022-08-13(c)
Under the Illinois Administrative Code, an imprisoned person's grievance must include "factual details regarding each aspect of the offender's complaint, including what happened, when, where and the name of each person who is the subject of or who is otherwise involved in the complaint. This provision does not preclude an offender from filing a grievance when the names of individuals are not known, but the offender must include as much descriptive information about the individual as possible." Ill. Admin. Code tit. 20, § 504.810(c). ... In this case, Morgan provided sufficient factual detail in his grievances. Like the plaintiffs in Dawson, Daval, and Cross, he did not identify anyone by name, but he clearly described how his TMJ treatment requests had been continuously denied. See Dawson, 2021 WL 3912273, at *6-8; Daval, 2021 WL 2072127, at *5-6; Cross, 2021 WL 1208970, at *6. Specifically, Morgan's grievances described the refusal of medical and other personnel to change his medication or provide him with an MRI screening or jaw surgery and their failure to provide him with the soft diet required by his TMJ.Read the full opinion on CourtListener →
Section 504.810(c) requires a grievance to provide factual details about what happened, when and where it happened, and the identities or descriptions of people involved; a grievance that does not identify the medical-care complaint is insufficient to exhaust that claim.
Anderson · filed 2025-11-03(c)
Illinois regulations provide that grievances “shall contain factual details regarding each aspect of the offender’s complaint, including what happened, when, where and the name of each person who is the subject of or who is otherwise involved in the complaint.” Ill. Admin. Code tit. 20, § 504.810(c). ... Plaintiff’s grievance, therefore, did not intelligibly convey a shortcoming with Dr. Bautista’s treatment.Read the full opinion on CourtListener →
Section 504.810(b) requires a grievance to give factual details about each aspect of the complaint, including what happened, when and where it happened, and the name of each person complained about.
Ward v. Hoffman · filed 2016-11-10(b)
Illinois law specifies that a prisoner’s grievances must “contain factual details regarding each aspect of the offender’s complaint, including what happened, when, where, and the name of each person who is the subject of ... the complaint.” Ill. Admin. Code tit. 20, § 504.810(b).Read the full opinion on CourtListener →
Grievance filing deadline—discovery of issue
Subsection (a) starts the 60-day grievance-filing period when the inmate discovers the issue, rather than necessarily when the underlying conduct occurred.
Margarella v. Chamberlain · filed 2020-12-04(a)
Moreover, the administrative code starts the clock only when a plaintiff “discovered” his medical issues. 20 Ill. Admin. Code § 504.810(a). Although the two medications at issue were prescribed in April and May 2016 respectively, Plaintiff did not learn of the adverse drug interaction until December 16, 2016, when the KSB doctor informed him that the interaction between these two prescriptions caused or contributed to his second heart attack. Plaintiff then submitted a grievance on December 18, 2016. Plaintiff could not reasonably have been expected to know of the alleged violation within the normal 60-day timeframe because the violation only became apparent after being treated by the KSB doctor. As a result, the Court finds that Defendants are unable to prove a failure to exhaust based on the timeliness issue.Read the full opinion on CourtListener →
Section 504.810(a) sets a 60-day grievance deadline but requires an untimely grievance to be considered when the offender shows good cause, allowing prison officials to exercise discretion to reach its merits.
Anderson v. Rabideau · filed 2022-09-26(a)
Id. at *4 (citing Ill. Admin. Code tit. 20, § 504.810(a), which concerns the initial steps in the grievance process and provides that grievances must be filed within 60 days of the discovery of the problem grieved, but further states that “if an offender can demonstrate that a grievance was not timely filed for good cause, the grievance shall be considered.”). ... Ultimately, the court in Kane found that when a Grievance Officer addresses a grievance on the merits rather than procedural grounds, “the ARB cannot later examine the grievance based on procedural grounds and cure the error.” ... Adopting this reasoning, this Court finds that prison officials utilized their discretion to consider Plaintiff’s grievance on the merits. Plaintiff timely appealed the CAO’s denial of the grievance to the ARB. Therefore, the Court declines to grant summary judgment based upon the ARB’s determination of untimeliness or any failure to exhaust.Read the full opinion on CourtListener →
Section 504.810(a) requires an inmate to file a grievance within 60 days after discovering the incident, and an ongoing violation may be grieved without stating a specific incident date.
Adams v. Larson · filed 2023-03-27(a)
However, section 504.180 does not require that an inmate include a specific date on the grievance, but that a grievance be submitted within 60 days of the discovery of the incident that formed the basis for it. See Ill. Admin. Code tit. 20, § 504.810 (grievance must be filed within 60 days after the discovery of the incident). Here, Plaintiff submitted the first grievance regarding the denial of double bedding on February 9, 2020, and although he did not provide a date on which Larson denied him a permit for double bedding, he had only been an inmate at the facility since January 29, 2020. Thus, he grieved the issue within 60 days of it occurring. Moreover, the grievance makes clear that he continues to be denied double bedding, thus the issue is ongoing and occurring on the day he submitted the grievance. Therefore, Plaintiff complied with section 504.810, and exhausted the administrative remedies available to him.Read the full opinion on CourtListener →
Section 504.810(a) requires an IDOC inmate to file a written grievance within 60 days of the incident or problem being grieved.
Bilik v. Hardy · filed 2023-06-07(a)
An IDOC inmate must file a written grievance within 60 days of the incident or problem being grieved.Read the full opinion on CourtListener →
Grievance specificity and identification of officials
Section 504.810(b) requires an inmate’s grievance to give factual details about the complained-of events and identify involved officials, or provide as much descriptive information as possible when an official’s name is unknown; it requires exhaustion of each issue, not a separate grievance against each defendant.
Cross, Sr. v. Pfister · filed 2021-03-31(b)
Illinois regulations provide that a prisoner’s grievance must provide factual details about the events that formed the basis for his complaint, including the names of each official involved. Ill. Admin. Code tit. 20., § 504.810(b). When a prisoner does not know an official’s name, he “must include as much descriptive information about the individual as possible.” Id. § 504.810(b). ... But this Court does not read Roberts as imposing a requirement on prisoners to file grievances against each individual defendant before filing a lawsuit. ... Cross was required to exhaust his remedies with respect to each issue raised in his complaint, not to exhaust his claims with respect to each individual Defendant. The Court declines to grant summary judgment on that basis.Read the full opinion on CourtListener →
Identifying individuals involved in a grievance
Section 504.810(a) requires a prisoner to identify the individuals involved in a grievance, or provide as much descriptive information as possible if their names are unknown.
Lyke v. Lank · filed 2022-08-15(a)
The grievance procedures require that an inmate name the individuals involved in the complaint, or, if their names are not known, an inmate, must at the very least, “include as much descriptive information about the individual as possible.” 20 Ill. Admin Code § 504.810(a)(b). ... Thus, the Court finds that although Plaintiff may not have named the individual Defendants in his grievances, this fact alone does not justify entry of summary judgment in this case for failure to exhaust administrative remedies before filing suit, particularly when the failure to identify the individuals was not a basis for denying the grievance at the administrative level.Read the full opinion on CourtListener →
Required details in prison grievances
Section 504.810(b) requires a prisoner’s grievance to include factual details such as the date of the incident and the names or descriptive information of involved individuals.
Venson v. Russell · filed 2022-10-14(b)
IDOC regulations require prisoners to include factual details in their grievances, including the names of the people involved in the incident or, if their identities are unknown, descriptive information about the individuals. Ill. Admin. Code tit. 20, § 504.810(b). ... Since none of these documents reference a failure to identify responsible individuals as the reason for denying Venson’s claim, that failure provides no basis to find that Venson did not exhaust her administrative remedies. ... IDOC regulations direct prisoners to include factual details in their grievances, including the date when the incident occurred. Ill. Admin. Code tit. 20, § 504.810(b). ... Considering the conflicting messages she received in response to her September 2018 grievance, the Court finds that administrative remedies were unavailable to Venson.Read the full opinion on CourtListener →
Section 504.810(c) requires factual details about what happened, when, where, and the people involved, but it does not strictly require specific dates when a grievance identifies an ongoing issue.
Wimberly v. Gomez · filed 2025-11-14(c)
But the Administrative Code does not strictly require dates. Instead, the Code requires “factual details regarding … what happened, when, where and the name of each person who is the subject of or who is otherwise involved in the complaint.” Ill. Admin. Code tit. 20, § 504.810(c). In the grievance, Wimberly explained the “when”: his inadequate access to his inhaler was a “continuous[]” and “ongoing” issue that has affected him “for many years.” ... Because Wimberly’s grievance identified an ongoing issue, his omission of any specific date does not mean that he failed to comply with procedural requirements.Read the full opinion on CourtListener →
Grievance filing deadlines and identification of involved persons
Section 504.810(a) gives an inmate 60 days to file a grievance after discovering the problem, while § 504.810(c) requires identifying or describing each person involved; omission is only a technical defect when prison officials do not reject the grievance on that basis.
Anderson v. Jeffreys · filed 2022-12-01(a), (c)
The time frame for Anderson to file a grievance about any of the events that underly his claims in this case was 60 days from discovering “the incident, occurrence or problem that [gave] rise to the grievance.” Ill. Admin. Code tit. 20, § 504.810(a). ... Section 504.810(c) requires a prisoner to name or describe “each person who is the subject of or who is otherwise involved in the complaint” being made. Ill. Admin. Code tit. 20, § 504.810(c). ... But the IDOC Defendants could not have been the subject of the complaints Anderson made in October 2018 and April 2019, as none of them were working in a relevant capacity at JTC (if at all) at those times. ... In other words, we do not read § 504.810(c) as requiring a prisoner to peer into the future to describe wrongdoing that has not yet occurred and name the individuals who will commit that wrongdoing, which is essentially what the IDOC Defendants’ reading of § 504.810(c) would require. ... A grievance’s failure to name or describe a defendant as required by § 504.810(c) amounts to a “mere technical defect” if the prison does not reject the grievance based on that failure. ... Thus, the grievances’ failure to name or describe the IDOC Defendants alone does not mean that Anderson failed to exhaust his remedies against them.Read the full opinion on CourtListener →
Time limit for filing a grievance
Section 504.810 requires a prisoner to file a grievance within six months of the occurrence giving rise to it.
Jones v. Detella · filed 1998-07-14
The Illinois Administrative Code requires that Jones file a grievance within six months of the occurrence which gives rise to the grievance.Read the full opinion on CourtListener →
7 more cases cited this section only in passing
These cases mention the section without interpreting it (a string cite, a footnote, background). Listed so you can see the full citation record, not just the annotated rulings.
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