Woodford v. Ngo
Supreme Court of the United States
March 22, 2006, Argued ; June 22, 2006, Decided
[*83] [**2382] Justice Alito delivered the opinion of the Court.
LEdHN[1A] [1A] This case presents the question whether HN1 a prisoner can satisfy the Prison Litigation Reform Act's exhaustion requirement, 42 U.S.C. § 1997e(a), by filing an untimely or otherwise procedurally defective administrative grievance or [*84] appeal. We hold that proper exhaustion of administrative remedies is necessary.
Congress enacted the Prison Litigation Reform Act of 1995 (PLRA), 110 Stat. 1321-71, as amended, 42 U.S.C. § 1997e et seq., in 1996 in the wake of a sharp rise in prisoner litigation in the federal courts, see, e.g., Alexander v. Hawk, 159 F.3d 1321, 1324-1325 (CA11 1998) (citing statistics). The PLRA contains a variety of provisions designed to bring this litigation under control. See, e.g., § 1997e(c) (requiring district courts to weed out prisoner [****6] claims that clearly lack merit); § 1997e(e) (prohibiting claims for emotional injury without prior showing of physical injury); § 1997e(d) (restricting attorney's fees).
A centerpiece of the PLRA's effort "to reduce the quantity . . . of prisoner suits" is an "invigorated" exhaustion provision, § 1997e(a). Porter v. Nussle, 534 U.S. 516, 524, 122 S. Ct. 983, 152 L. Ed. 2d 12 (2002). Before 1980, prisoners asserting constitutional claims had no obligation to exhaust administrative remedies. See Wilwording v. Swenson, 404 U.S. 249, 251, 92 S. Ct. 407, 30 L. Ed. 2d 418 (1971) (per curiam). In the Civil Rights of Institutionalized Persons Act, § 7, 94 Stat. 349, 352, 353, Congress enacted a weak exhaustion provision, which authorized district courts to stay actions under Rev. Stat. § 1979, 42 U.S.C. § 1983, for a limited time while a prisoner exhausted "such plain, speedy, and effective administrative remedies as are available." § 1997e(a)(1) (1994 ed.). "Exhaustion under the 1980 prescription was in large part discretionary; it could be ordered only if the State's prison grievance system met specified federal standards, and even then, only if, in the particular case, the court believed [****7] the requirement 'appropriate [***375] and in the interests of justice.'" Nussle, supra, at 523, 122 S. Ct. 983, 152 L. Ed. 2d 12 (quoting § 1997e). In addition, this provision did not require exhaustion if the prisoner sought only money damages and such [*85] relief was not available under the relevant administrative scheme. See McCarthy v. Madigan, 503 U.S. 140, 150-151, 112 S. Ct. 1081, 117 L. Ed. 2d 291 (1992).
LEdHN  The PLRA strengthened this exhaustion provision in several ways. Exhaustion is no longer left to the discretion of the district court, but is mandatory. See Booth v. Churner, 532 U.S. 731, 739, 121 S. Ct. 1819, 149 L. Ed. 2d 958 (2001). Prisoners must now exhaust all "available" remedies, not just those that meet federal standards. Indeed, as we held in Booth, a [**2383] prisoner must now exhaust administrative remedies even where the relief sought--monetary damages--cannot be granted by the administrative process. Id., at 734, 121 S. Ct. 1819, 149 L. Ed. 2d 958. Finally, exhaustion of available administrative remedies is required for any suit challenging prison conditions, not just for suits under § 1983. Nussle, supra, at 524, 122 S. Ct. 983, 152 L. Ed. 2d 12. Read The Full CaseNot a Lexis Advance subscriber? Try it out for free.
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548 U.S. 81 *; 126 S. Ct. 2378 **; 165 L. Ed. 2d 368 ***; 2006 U.S. LEXIS 4891 ****; 19 Fla. L. Weekly Fed. S 332
JEANNE S. WOODFORD, et al., Petitioners v. VIET MIKE NGO
Subsequent History: [****1] On remand at Viet Ngo v. J. S. Woodford, 539 F.3d 1108, 2008 U.S. App. LEXIS 17819 (9th Cir. Cal., Aug. 21, 2008)
Prior History: ON WRIT OF CERTIORARI TO THE UNITED STATES COURT OF APPEALS FOR THE NINTH CIRCUIT.
Ngo v. Woodford, 403 F.3d 620, 2005 U.S. App. LEXIS 4809 (9th Cir. Cal., 2005)
Disposition: Reversed and remanded.
exhaustion, grievance, procedural default, federal court, prison, required to exhaust, administrative remedy, proceedings, inmate, bypass, suits, courts, prison official, remedies, exhaustion of administrative remedies, deliberate, deadlines, procedural error, frivolous, Appeals, constitutional claim, rules of procedure, meritorious, judge-made, purposes, quantity, untimely, engraft, parties, wording
Civil Rights Law, Prisoner Rights, Prison Litigation Reform Act, Exhaustion of Administrative Remedies, Administrative Law, Judicial Review, Reviewability, Exhaustion of Remedies, Criminal Law & Procedure, Procedural Defenses, Exhaustion of Remedies, Satisfaction of Exhaustion, Order & Timing of Petitions, Procedural Default, General Overview