Woodford et al. v. Ngo
548 U.S. 81 (2006)
Rule of Law:
The Prison Litigation Reform Act's (PLRA) exhaustion requirement, 42 U.S.C. § 1997e(a), requires 'proper exhaustion,' meaning a prisoner must comply with all of an administrative grievance system's procedural rules, including deadlines, as a precondition to filing suit in federal court.
Facts:
- Respondent Ngo, a prisoner in the California prison system, was placed in administrative segregation in October 2000.
- Two months later, Ngo was returned to the general prison population but was prohibited from participating in various 'special programs,' including religious activities.
- Approximately six months after this restriction was imposed, Ngo filed a grievance with prison officials challenging the action.
- The grievance was rejected by prison officials as untimely because it was not filed within the 15-working-day limit prescribed by the prison's rules.
- Ngo's subsequent internal appeals of the timeliness rejection were also denied.
Procedural Posture:
- Respondent Ngo filed a lawsuit under 42 U.S.C. § 1983 against California correctional officials in the U.S. District Court (a trial court).
- The District Court granted the petitioners' motion to dismiss, ruling that Ngo had failed to properly exhaust his administrative remedies.
- Ngo, as appellant, appealed the dismissal to the U.S. Court of Appeals for the Ninth Circuit.
- The Ninth Circuit, with the officials as appellees, reversed the District Court's decision, holding that Ngo had exhausted his remedies because they were no longer available to him.
- The correctional officials, as petitioners, were granted a writ of certiorari by the U.S. Supreme Court.
Premium Content
Subscribe to Lexplug to view the complete brief
You're viewing a preview with Rule of Law, Facts, and Procedural Posture
Issue:
Does a prisoner satisfy the exhaustion requirement of the Prison Litigation Reform Act (PLRA), 42 U.S.C. § 1997e(a), by filing an administrative grievance that is untimely or otherwise procedurally defective under the applicable prison rules?
Opinions:
Majority - Justice Alito
No. The Prison Litigation Reform Act (PLRA) requires proper exhaustion of administrative remedies, which means a prisoner must comply with the prison's procedural rules, including deadlines, before bringing suit in federal court. The Court reasoned that the term 'exhausted' in § 1997e(a) should be interpreted consistently with its meaning in administrative law, where it signifies proper exhaustion, not merely the unavailability of further remedies. This interpretation is necessary to fulfill the PLRA's objectives: giving correctional officials a fair opportunity to address complaints internally, reducing the quantity of prisoner litigation, and improving the quality of suits that are filed by creating a useful administrative record. Allowing prisoners to bypass these rules by filing untimely or defective grievances would render the exhaustion requirement 'a largely useless appendage' and create a 'toothless scheme' that prisoners could easily circumvent.
Concurring - Justice Breyer
I agree with the majority that the PLRA requires proper exhaustion and that untimely grievances do not satisfy this requirement. However, this requirement is not absolute. The well-established doctrine of administrative exhaustion includes several traditional exceptions, such as futility, hardship, or the inadequacy of administrative remedies. On remand, the lower court should be able to consider whether the prisoner's case falls into one of these traditional exceptions that the statute implicitly incorporates, which would excuse the failure to properly exhaust.
Dissenting - Justice Stevens
Yes. A prisoner satisfies the PLRA's exhaustion requirement as long as administrative remedies are no longer 'available,' regardless of the reason for their unavailability. The plain text of the statute requires only exhaustion of 'available' remedies and does not contain language mandating 'proper' exhaustion or creating a procedural default sanction. The majority incorrectly imports a judge-made procedural default rule from administrative law, which is inappropriate because prisoner § 1983 suits are de novo proceedings, not appellate reviews of agency action. This judicially created rule will harshly bar meritorious claims due to minor procedural errors made by pro se prisoners, frustrating Congress's intent to filter frivolous claims while preserving legitimate ones.
Analysis:
This decision significantly strengthens the procedural hurdles for prisoners seeking to file lawsuits regarding prison conditions. By defining 'exhaustion' under the PLRA as 'proper exhaustion,' the Court created a de facto procedural default rule that is not explicitly stated in the statute's text. This holding mandates that prisoners must strictly adhere to the administrative grievance procedures established by corrections officials, effectively making those internal rules a prerequisite for access to federal court. The decision gives prison systems substantial control over the gateway to litigation and is likely to result in the dismissal of many prisoner lawsuits on procedural grounds before the merits of their claims are ever considered.
Gunnerbot
AI-powered case assistant
Loaded: Woodford et al. v. Ngo (2006)
Try: "What was the holding?" or "Explain the dissent"