Jones v. Michigan Dept. of Corrections
Issues
Does the Prison Litigation Reform Act (PLRA), which requires that prisoners first exhaust all available administrative remedies prior to filing a civil rights suit in federal court, mandates that a prisoner's entire civil suit be dismissed from federal court if the prisoner has failed to totally exhaust all available administrative remedies for each claim prior to filing suit? Additionally, does a prisoner, who proceeds to file suit in federal court but fails to attach to his complaint proof and documentation of how he exhausted all available administrative remedies, must have his entire case dismissed from federal court? Finally, does a prisoner's entire civil rights case must be dismissed from federal court if, during the process of exhausting available administrative remedies, he failed to specifically name the parties whom he later named as defendants in his federal court case?
Lorenzo Jones and Timothy Williams both filed suit against the Michigan Department of Corrections on the grounds that the treatment they received in jail violated their Constitutional civil rights. The Circuit Court held that neither plaintiff fulfilled their requirements to totally exhaust available administrative remedies under 42. U.S.C. § 1997e of the PLRA. The Circuit Court held that Jones failed the exhaustion requirement because he failed to either describe or attach proof of how he exhausted administrative remedies in his complaint. See Jones v. Bock, 135 Fed at 839. Although Williams did attach proof of exhaustion to his complaint, the Circuit Court held that he still failed the PLRA’s exhaustion requirement because he did not specifically name the defendant in his initial grievance filings with prison officials. See Williams v. Overton, 136 Fed at 862. In these consolidated cases, Petitioners argue that the Circuit Court's holdings amount to judicially-created pleading requirements that are inconsistent with the PLRA’s text, the Federal Rules of Civil Procedure, and judicial norms. Respondents maintain that the PLRA instituted a “new regime” for inmate Civil Rights Act suits and that the text and structure of the PLRA require the Circuit Court’s heightened pleading requirements. See Brief for Respondents at 27-28. How the Supreme Court decides these condensed cases will reflect its view of the correct balance of burden between inmate plaintiffs and the judiciary. These cases will either require prisoners to be more vigilant in asserting their own civil rights or require the judiciary to be more active in defending prisoners’ rights.
Questions as Framed for the Court by the Parties
Jones v. Michigan Dept. of Corrections:
1. Whether satisfaction of the PLRA’s exhaustion requirement is a prerequisite to a prisoner's federal civil rights suit such that the prisoner must allege in his complaint how he exhausted his administrative remedies (or attach proof of exhaustion to the complaint), or instead, whether non-exhaustion is an affirmative defense that must be pleaded and proven by the defense.
2. Whether the PLRA prescribes a “total exhaustion” rule that requires a federal district court to dismiss a prisoner's federal civil rights complaint for failure to exhaust administrative remedies whenever there is a single unexhausted claim, despite the presence of other exhausted claims.
Williams v. Overton:
1. Whether the PLRA requires a prisoner to name a particular defendant in his or her administrative grievance in order to exhaust his or her administrative remedies as to that defendant and to preserve his or her right to sue them.
2. Whether the PLRA prescribes a “total exhaustion” rule that requires a federal district court to dismiss a prisoner's federal civil rights complaint for failure to exhaust administrative remedies whenever there is a single unexhausted claim, despite the presence of other exhausted claims.
Purpose and Effect of the PLRA
If a prisoner feels that his civil rights have been violated during his incarceration, he has a right to file a civil rights claim in federal court. Each year, thousands of prisoners commence actions on these grounds. The Prison Litigation Reform Act of 1995 (“PLRA”), which was passed by Congress in 1996, was designed in response to an influx of prisoner civil rights litigation.