Washington v. Barr - 925 F.3d 109 (2d Cir. 2019)

Rule:

Exhaustion of administrative remedies is a doctrine that holds that federal courts should refrain from adjudicating a controversy if the party bringing suit might obtain adequate relief through a proceeding before an administrative agency. No one is entitled to judicial relief for a supposed or threatened injury until the prescribed administrative remedy has been exhausted. The duty to exhaust administrative remedies can spring from legislation or from judicial decision. Where Congress specifically mandates it, exhaustion is required. But even where Congress has not clearly required exhaustion, a court may still impose it as an act of sound judicial discretion.

Facts:

Plaintiffs initiated a suit in the Southern District of New York, raising numerous arguments for re- or descheduling marijuana. Plaintiffs argued that the new facts related to the acceptance of medical marijuana treatment regimens and the federal government's own involvement in medical marijuana research required a reexamination of marijuana's scheduling under the Controlled Substances Act (CSA). Defendants moved to dismiss, which the district court granted. The district court held that plaintiffs had failed to exhaust their administrative remedies and that they did not qualify for an exception to the exhaustion rule.

Issue:

Did the plaintiffs fail to exhaust their administrative remedies, thereby justifying the dismissal of the plaintiffs’ action?

Answer:

Yes.

Conclusion:

The decision was affirmed. The court held that the plaintiffs failed to exhaust their administrative remedies. Although not mandated by Congress, requiring exhaustion was appropriate because it was consistent with congressional intent, as manifested in the CSA's text and structure, and it advanced the goals served by the exhaustion doctrine. None of the recognized exceptions to the exhaustion doctrine applied, particularly as the existing classificatory scheme had not prevented plaintiffs from obtaining their medication and they did not show how pursuing agency review would subject them to injury from delay incident to the administrative process.