Booth v. Churner - 532 U.S. 731, 121 S. Ct. 1819 (2001)

Rule:

The Prison Litigation Reform Act of 1995 amends 42 U.S.C.S. § 1997e(a), and requires a prisoner to exhaust such administrative remedies as are available before suing over prison conditions. 

Facts:

The Prison Litigation Reform Act of 1995 amended 42 U.S.C. § 1997e(a), which now requires a prisoner to exhaust "such administrative remedies as are available" before suing over prison conditions. Petitioner Booth was a Pennsylvania state prison inmate when he began this 42 U.S.C. § 1983 action in Federal District Court, claiming that respondent corrections officers violated his Eighth Amendment right to be free from cruel and unusual punishment by assaulting him, using excessive force against him, and denying him medical attention to treat ensuing injuries. He sought various forms of injunctive relief and money damages. At the time, Pennsylvania provided an administrative grievance and appeals system, which addressed Booth's complaints but had no provision for recovery of money damages. Before resorting to federal court, Booth filed an administrative grievance, but did not seek administrative review after the prison authority denied relief. Booth's failure to appeal administratively led the District Court to dismiss the complaint without prejudice for failure to exhaust administrative remedies under § 1997e(a). The Third Circuit affirmed, rejecting Booth's argument that the exhaustion requirement is inapposite to his case because the administrative process could not award him the monetary relief he sought.

Issue:

Did Subsection (a) of 42 USCS 1997e require Booth to complete prison administrative process before suing over prison conditions even though Booth sought only money damages not recoverable through such process?

Answer:

Yes

Conclusion:

The United States Supreme Court held that, even though the administrative procedure could not provide Booth’s requested monetary relief, the Prison Litigation Reform Act of 1995 nonetheless required Booth to exhaust his administrative remedies before filing suit. The required exhaustion of available remedies did not imply that the remedy must provide the requested relief, but rather indicated that whatever procedural means were available had to be exhausted. Further, the statutory elimination of the requirement that the remedy be effective also supported the conclusion that Booth had to exhaust prison administrative remedies irrespective of the forms of relief sought and offered through administrative avenues.