McCarthy v. Madigan

Rule of Law:

A federal prisoner seeking only money damages for a constitutional violation is not required to exhaust the Federal Bureau of Prisons' internal administrative grievance procedure before filing a Bivens action in federal court, because the procedure cannot provide the monetary relief sought.

Facts:

• John J. McCarthy was a prisoner in the federal penitentiary at Leavenworth with a history of psychiatric problems and a medical condition resulting from a back operation.
• McCarthy alleged that four prison employees—the hospital administrator, the chief psychologist, another psychologist, and a physician—were deliberately indifferent to his medical needs.
• McCarthy contended that this deliberate indifference violated his Eighth Amendment constitutional rights.
• The Federal Bureau of Prisons maintains a general “Administrative Remedy Procedure for Inmates” to allow prisoners to seek formal review of complaints related to their imprisonment.
• This administrative procedure has a series of short, successive deadlines for filing complaints and appeals.
• The administrative grievance procedure does not authorize the award of money damages to prisoners.

Procedural Posture:

• John J. McCarthy filed a pro se complaint in the U.S. District Court for the District of Kansas against four prison employees, seeking only money damages.
• The District Court, a trial court, dismissed the complaint on the ground that McCarthy had failed to exhaust the prison's administrative remedies.
• McCarthy filed a motion for reconsideration, which the District Court denied.
• McCarthy appealed the dismissal to the U.S. Court of Appeals for the Tenth Circuit, where he was the appellant.
• The Court of Appeals, an intermediate appellate court, affirmed the District Court's dismissal.
• The U.S. Supreme Court granted certiorari to resolve a conflict among the circuit courts.