Woodford v. Ngo
Issues
Does the rejection of a prisoner’s grievance on procedural grounds, due to the untimely nature of the claim, bar the prisoner’s constitutional claims from federal court under the Prison Litigation Reform Act’s requirement that prisoners exhaust all administrative remedies before filing suit?
In 2000, California state prisoner Viet Mike Ngo was placed in administrative segregation for alleged misconduct. Following his release, he was prevented from taking part in certain programs deemed critical for parole eligibility. Ngo submitted a formal grievance that was time-barred by the Appeals Coordinator because it was not filed within the requisite 15 working days after the event. Under the Prison Litigation Reform Act (“PLRA”), prisoners are prevented from filing suit until administrative remedies are exhausted. The District Court ruled that Ngo failed to exhaust his remedies under PLRA and was therefore precluded from seeking federal relief. The Ninth Circuit Court of Appeals reversed the decision, holding that Ngo exhausted all remedies as required by the PLRA. The Supreme Court will address whether an untimely administrative appeal satisfies this exhaustion requirement under PLRA.
Questions as Framed for the Court by the Parties
Does a prisoner satisfy the Prison Litigation Reform Act’s administrative exhaustion requirement by filing an untimely or otherwise procedurally defective administrative appeal?
Respondent Viet Mike Ngo is a prisoner serving a life sentence in California. Brief for the United States as Amicus Curiae Supporting Petitioners, at 1. On October 26, 2000, Ngo, an inmate at San Quentin State Prison, was placed in administrative segregation as punishment for alleged “inappropriate activity” with Catholic volunteer priests. Brief for Respondent at 2, .
Additional Resources
- Law about... Prisoners' Rights