Supreme Court Decision in Jones v. Bock: Exhaustion Requirements under the Prison Litigation Reform Act
Publication Date: March 2007
Publisher(s): Library of Congress. Congressional Research Service
Congress passed the Prison Litigation Reform Act (PLRA) to help reduce the strain on the federal judicial system of extensive inmate litigation. The act mandated exhaustion of federal and state administrative remedies before an inmate could file a civil rights action. The Sixth Circuit along with some other lower courts adopted several procedural rules designed to implement this exhaustion requirement and facilitate early judicial screening. The Supreme Court granted certiorari to resolve the conflict in Jones v. Bock, and two other consolidated cases, namely: Walton v. Bouchard, and Williams v. Overton, which it unanimously decided that failure to exhaust prison grievance procedures is an affirmative defense, thereby rejecting the Court of Appeals' procedural rules as exceeding the proper limits of the judical role.
The issues in these cases were: (1) whether the PLRA prescribes "total exhaustion" that requires a federal court to dismiss a prisoner's federal civil rights complaint for failure to exhaust his administrative remedies whenever there is a single unexhausted claim, despite the presence of other exhausted claims; (2) 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; and (3) 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 and document in his complaint how he exhausted his administrative remedies, or instead, whether non-exhaustion is an affirmative defense that must be pled and proved by the defense.
The Supreme Court decided these three issues on January 22, 2007 in favor of inmate litigants, rejecting various exhaustion screening mechanisms adopted by some of the circuits and thus making it less difficult for inmates/plaintiffs to pursue lawsuits involving complaints about their treatment in prison. It remains to be seen what impact this will have on the workload of the federal courts which already consists of tens of thousands of inmate civil rights cases a year.