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To properly exhaust administrative remedies, prisoners must complete the administrative review process in accordance with the applicable procedural rules -- rules that are defined not by the Prison Litigation Reform Act of 1995 (PLRA); but, by the prison grievance process itself. Compliance with prison grievance procedures, therefore, is all that is required by the PLRA to "properly exhaust." The level of detail necessary in a grievance to comply with the grievance procedures will vary from system to system and claim to claim, but it is the prison's requirements, and not the PLRA, that define the boundaries of proper exhaustion.
Petitioner inmates' filed suits under 42 U.S.C.S. § 1983 against defendant prison officials. The district courts dismissed the respective cases for inmates' failure to exhaust administrative remedies and to adequately plead exhaustion in their complaints in compliance with the PLR . All judgments were affirmed by the Court of Appeals. The inmates allegedly failed to comply with the Prison Litigation Reform Act of 1995 (PLRA), which requires prisoners to exhaust prison grievance procedures with respect to prison conditions before filing suit. The judgments of the United States Court of Appeals for the Sixth Circuit were reversed, and the cases were remanded.
Did petitioners fail to exhaust all administrative remedies in accordance to PLRA?
The PLRA did not state exhaustion had to be pleaded by the inmate, thus evidencing that the usual practice which was to regard exhaustion as an affirmative defense should be followed. The screening requirement did not justify deviating from the usual procedure beyond that in the PLRA. There was no basis to conclude that Congress implicitly transformed exhaustion from an affirmative defense to a pleading requirement by specifying that courts should screen PLRA complaints and dismiss those that failed to state a claim. Section 1997e(g)(1) allowed defendants to waive responses without admitting the allegations notwithstanding any other law or procedural rule, thus showing that when Congress meant to depart from the usual procedure, it did so expressly. Failure to exhaust was an affirmative defense under the PLRA, and inmates were not required to plead exhaustion in their complaints. The rule that each defendant later sued had to have been named in initial grievances lacked a textual basis in the PLRA and prison policy did not specify who a grievance had to name. Dismissal under the total exhaustion rule was error as failure to exhaust one claim did not necessarily affect others.