Thursday, June 22, 2006

SCOTUS Holds that PLRA’s Exhaustion Requirement Requires Proper Exhaustion of Administrative Remedies

Per Woodford v. Ngo, No. 05–416 (Jun. 22, 2006) [From the Syllabus]:

The Prison Litigation Reform Act of 1995 (PLRA) requires a prisoner to exhaust any available administrative remedies before challenging prison conditions in federal court. 42 U. S. C. §1997e(a). Respondent filed a grievance with California prison officials about his prison conditions, but it was rejected as untimely under state law. He subsequently sued petitioner officials under §1983 in the Federal District Court, which granted petitioners’ motion to dismiss on the ground that respondent had not fully exhausted his administrative remedies under §1997e(a). Reversing, the Ninth Circuit held that respondent had exhausted those remedies because none remained available to him.

Held: The PLRA’s exhaustion requirement requires proper exhaustion of administrative remedies.

(a) Petitioners claim that a prisoner must complete the administrative review process in accordance with applicable procedural rules, including deadlines, as a precondition to bringing suit in federal court, but respondent contends that §1997e(a) allows suit once administrative remedies are no longer available, regardless of the reason. To determine the correct interpretation, the Court looks for guidance to both administrative and habeas corpus law, where exhaustion is an important doctrine. Administrative law requires proper exhaustion of administrative remedies, which “means using all steps that the agency holds out, and doing so properly.” Pozo v. McCaughtry, 286 F. 3d 1022, 1024. Habeas law has substantively similar rules, though its terminology is different. Pp. 5–11.

(b) Given this background, the Court is persuaded that the PLRA requires proper exhaustion. Pp. 11–17.

Alito, J., delivered the opinion of the Court, in which Roberts, C. J., and Scalia, Kennedy, and Thomas, JJ., joined. Breyer, J., filed an opinion concurring in the judgment. Stevens, J., filed a dissenting opinion, in which Souter and Ginsburg, JJ., joined.


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