Prison Litigation Reform Act Case Study

The Prison Litigation Reform Act (“PLRA”) generally requires a prisoner Plaintiff to exhaust administrative remedies before filing suit in federal court. Title 42 U.S.C. § 1997e(a) provides that “[n]o action shall be brought with respect to prison conditions under § 1983 of this title, or any other Federal law by a prisoner confined in any jail, prison, or other correctional facility until such administrative remedies as are available are exhausted.” See also Moore v. Bennette, 517 F.3d 717, 725 (4th Cir. 2008). The Supreme Court has interpreted the language of this provision broadly, holding that the phrase “prison conditions” encompasses “all inmate suits about prison life, whether they involve general circumstances or particular episodes, and whether they allege excessive force or some other wrong.” Porter v. Nussle, 532 U.S. 516, 532 (2002). Exhaustion is mandatory and unexhausted claims may not be brought in court. Thus, the exhaustion provision plainly extends to the Plaintiff’s allegations, and his claim should be dismissed unless he has satisfied the administrative exhaustion requirement under the PLRA.
The PLRA’s exhaustion requirement compels a prisoner to comply with prison grievance procedures. Jones v.
See Booth v. Churner, 532 U.S. 731, 735 (2001) (affirming dismissal of prisoner’s claim for failure to exhaust where he “never sought intermediate or full administrative review after prison authority denied relief”); Thomas v. Wollum, 337 F.3d 720, 726 (6th Cir. 2003) (noting that a prisoner must appeal administrative rulings “to the highest possible administrative level”); Gibbs v. Bureau of Prisons, 986 F.Supp. 941, 943-44 (D.Md. 1997) (dismissing a lawsuit for failure to exhaust, where a federal prisoner did not appeal his administrative claim through all four stages of the BOP’s grievance