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The Prison Litigation Reform Act of 1995 mandates that an inmate exhaust such administrative remedies as are available before bringing suit to challenge prison conditions. 42 U.S.C.S. § 1997e(a).
Two guards--James Madigan and petitioner Michael Ross--undertook to move respondent Shaidon Blake, a Maryland inmate, to the prison's segregation unit. During the transfer, Madigan assaulted Blake, punching him several times in the face. Blake reported the incident to a corrections officer, who referred the matter to the Maryland prison system's Internal Investigative Unit (IIU). The IIU, which has authority under state law to investigate employee misconduct, issued a report condemning Madigan's actions. Blake subsequently sued both guards under 42 U.S.C. §1983, alleging excessive force and failure to take protective action. A jury found Madigan liable. But Ross raised as an affirmative defense the exhaustion requirement of the Prison Litigation Reform Act of 1995 (PLRA), which demanded that an inmate exhaust “such administrative remedies as are available” before bringing suit to challenge prison conditions. Ross argued that Blake had filed suit without first following the prison's prescribed procedures for obtaining an administrative remedy, while Blake argued that the IIU investigation was a substitute for those procedures. The District Court sided with Ross and dismissed the suit. The Fourth Circuit reversed, holding that “special circumstances” can excuse a failure to comply with administrative procedural requirements--particularly where the inmate reasonably, even though mistakenly, believed he had sufficiently exhausted his remedies. Certiorari was granted.
Could “special circumstances” excuse an inmate’s failure to comply with administrative procedural requirements--particularly where the inmate reasonably, even though mistakenly, believed he had sufficiently exhausted his remedies?
The Court held that there was no common-law “special circumstances” exception relieving prison inmate of obligation, under Prison Litigation Reform Act provision (42 U.S.C.S. § 1997e(a)), to exhaust administrative remedies when the inmate erroneously believed he had satisfied exhaustion by participating in internal investigation. According to the Court, the language of 42 U.S.C.S. § 1997e(a) requiring administrative exhaustion was mandatory, and a pending internal investigation of the guard's conduct did not excuse the inmate from pursuing the prison grievance process. However, although exhaustion was required, it remained to determine whether an administrative remedy was available to the inmate since there was evidence indicating that grievances were routinely dismissed when parallel internal investigations were pending, and the prison's grievance process appeared to be inconsistent and somewhat bewildering. Accordingly, judgment was vacated and the case was remanded.