Thank You For Submiting Feedback!
The text of 42 U.S.C.S. § 1997e(a) strongly suggests that the Prison Litigation Reform Act uses the term "exhausted" to mean what the term means in administrative law, where exhaustion means proper exhaustion. 42 U.S.C.S. § 1997e(a) refers to "such administrative remedies as are available," and thus points to the doctrine of exhaustion in administrative law.
Respondent, a California state prisoner, challenging a disciplinary action that had been imposed on him approximately 6 months previously, appealed the action pursuant to California's prisoner-grievance system. The prison's appeals coordinator rejected the grievance as time-barred under the applicable state regulations, because the grievance had not been filed within 15 working days of the action being challenged. Respondent subsequently brought suit in the United States District Court for the Northern District of California under 42 U.S.C.S. § 1983 against some California correctional officials. The District Court, in granting the officials' motion to dismiss, said that the respondent had not fully exhausted his administrative remedies as required by a provision of the Prison Litigation Reform Act of 1995 (PLRA) (42 U.S.C.S. § 1997e(a)), which provided that no federal action may be brought by a prisoner with respect to prison conditions "until such administrative remedies as were available were exhausted." The United States Court of Appeals for the Ninth Circuit, in reversing, concluded that the respondent had exhausted his administrative remedies, as required by § 1997e(a)), simply because no such remedies had remained available to him; and § 1997e(a)) did not bar subsequent judicial consideration of an exhausted administrative appeal that was denied on state procedural grounds. The California correctional officials sought certiorari review, arguing that the PLRA's exhaustion requirement required respondent to complete the administrative review process in accordance with applicable procedural rules, including deadlines, as a precondition to bringing suit in federal court.
Did the PLRA's exhaustion requirement require respondent to complete the administrative review process in accordance with applicable procedural rules, including deadlines, as a precondition to bringing suit in federal court?
The Court looked for guidance to both administrative and habeas corpus law, and concluded that the PLRA required proper exhaustion. The Court found that the text of § 1997e(a) strongly suggested that the PLRA used the term "exhausted" to mean what the term meant in administrative law, where exhaustion meant proper exhaustion. According to the Court, construing § 1997e(a) to require proper exhaustion fit with the general scheme of the PLRA and served the PLRA's goals. The Court averred that a proposed interpretation of § 1997e(a), under which exhaustion would mean merely that administrative remedies were no longer available, regardless of the reason for unavailability, would (a) make the PLRA exhaustion scheme wholly ineffective, (b) be insufficient to filter out frivolous claims, and (c) be unprecedented in statutes or cases.