Booth v. Churner

PETITIONER: Booth
RESPONDENT: Churner
LOCATION: Office of Attorney General

DOCKET NO.: 99-1964
DECIDED BY: Rehnquist Court (1986-2005)
LOWER COURT: United States Court of Appeals for the Third Circuit

CITATION: 532 US 731 (2001)
ARGUED: Mar 20, 2001
DECIDED: May 29, 2001

ADVOCATES:
Gerald J. Pappert - Harrisburg, Pennsylvania, argued the cause for the respondents
Irving L. Gornstein - On behalf of the United States, as amicus curiae, supporting the respondents
Nancy Winkelman - Argued the cause for the petitioner

Facts of the case

The Prison Litigation Reform Act of 1995 requires a prisoner to exhaust "such administrative remedies as are available" before suing over prison conditions. Timothy Booth, an inmate at the State Correctional Institution at Smithfield, Pennsylvania, initiated a suit in District Court, claiming that corrections officers violated his Eighth Amendment right to be free from cruel and unusual punishment in various ways. Booth sought both injunctive relief and monetary damages. At the time of Booth's suit, Pennsylvania provided an administrative grievance and appeals system, which addressed Booth's complaints but had no provision for recovery of money damages. After the prison authority denied his administrative grievance, Booth did not seek administrative review. Subsequently, the District Court dismissed the complaint for failure to exhaust administrative remedies. In affirming, the Court of Appeals rejected Booth's argument that the exhaustion requirement was inapplicable because the administrative process could not award him the monetary relief he sought (At this point, Booth was only seeking money).

Question

Must prisoners who seek only monetary damages in suits over prison conditions still exhaust all administrative remedies before going to court, even if monetary damages are not available under the particular administrative process?

Media for Booth v. Churner

Audio Transcription for Oral Argument - March 20, 2001 in Booth v. Churner

Audio Transcription for Opinion Announcement - May 29, 2001 in Booth v. Churner

The opinion of the Court in No. 99-1964, Booth against Churner will be announced by Justice Souter.

David H. Souter:

This case comes to us on writ of certiorari to the United States Court of Appeals for the Third Circuit.

The Prison Litigation Reform Act of 1995 amended 42 U.S.C. Section 1997e(a).

That Section now requires a prisoner to exhaust what it calls such administrative remedies as are available before suing over prison conditions.

When the petitioner Booth sued the respondents who are a group of corrections officers under Section 1983 for alleged abuses, the District Court dismissed the complaint for failure on Booth’s part to exhaust administrative remedies.

The Third Circuit affirmed rejecting Booth’s argument that the exhaustion requirement does not apply to his case because the prison’s administrative process could not award him the monetary relief he sought when money was at that point the only relief he still requested.

We granted certiorari.

In a unanimous opinion filed today with the Clerk of the Court, we affirm the judgment of Third Circuit, and hold that under the statute an inmate seeking only money damages must still complete any prison administrative process capable of addressing the subject of the inmate’s complaint even if the process does not make specific provision for monetary relief.

The meaning of the phrase “such administrative remedies as are available” is the crux of the case.

Neither practical considerations nor other dictionary definitions of the words remedies and available urged by the parties are conclusive in seeking the congressional intend here.

Clearer clues have found in the broader statutory context in which Congress referred to “available” administrative “remedies”, and in the statutory history of this Section.

This history shows that exhaustion is required regardless of the relief offered through the administrative procedures.

Before Subsection A was amended a court had discretion to require an inmate to exhaust what the statute then called “such remedies as are available”, but only if the remedies were plain, speedy and effective in the statutory words.

Congress however, has eliminated both the discretion to dispense with administrative exhaustion and the condition that the remedy be effective before exhaustion can be required.

In McCarthy v. Madigan decided in 1992, we interpreted the requirement of an effective remedy so as to excuse exhaustion by those seeking only money damages when money was unavailable at the administrative level.

It has to be significant that Congress removed the very term effective that the McCarthy Court had previously emphasized in reaching the result that Booth now seeks, and the fair inference to be drawn is that congress meant to preclude the McCarthy result, which would be in Booth’s favor here.