Why is the case important?
Lorenzo Jones (P), a Michigan prisoner, suffered injuries while in prison, and sought a reassignment to other work he could do with his diminished capacity after the injuries. When the staff refused his request he sued the state.
Facts of the case
“Congress passed the Prisoner Litigation Reform Act (PLRA) in 1995 in an effort to cut down on frivolous lawsuits by prisoners. Under the PLRA, before bringing a federal civil rights suit a prisoner must go through his prison’s internal complaint process. Only after exhausting all of these “”administrative remedies”” can the prisoner bring the complaint to federal court.Lorenzo Jones sustained serious injuries in a car accident while in custody. He sued prison officials in federal court, claiming that they were violating his Eighth Amendment rights by making him do arduous work despite his injuries. The officials moved to dismiss the suit, because Jones had not provided any evidence or description of the administrative remedies he claimed to have pursued. The District Court granted the motion and dismissed the suit.On appeal, the U.S. Court of Appeals for the Sixth Circuit affirmed. The Circuit Court ruled that in order for Jones to sue, he would have had to provide the court with copies of his grievance forms or at least describe the administrative processes he had exhausted. The Circuit Court further ruled that the PLRA requires “”total exhaustion,”” which means that if a prisoner’s suit has multiple claims, administrative remedies must have been exhausted for each and every claim.The Supreme Court accepted review in order to resolve the conflict between Circuit Courts over which side bears the burden of proving exhaustion of administrative remedies.In Williams v. Overton , Timothy Williams suffered from a medical condition which caused tumor growth and disfigurement in his arm. He claimed that prison officials were violating his rights by ignoring his medical needs. Williams’s complaint had two claims: he needed additional surgery on his arm and a single-occupancy, handicapped-accessible cell. Williams went through the administrative remedial process on both grievances and both claims were denied. Williams then sued in federal court.The District Court dismissed the suit, because Williams had neglected to name any prison officials as defendants in his medical complaint. Therefore, the court ruled, the administrative remedies for that claim could not be considered to have been exhausted.On appeal, the U.S. Court of Appeals for the Sixth Circuit affirmed, ruling that “”The prisoner must demonstrate that he has exhausted the administrative remedies with respect to each individual he intends to sue.”” The Circuit Court also ruled that the PLRA requires “”total exhaustion,”” which meant that Williams’s entire suit was dismissed because of his unexhausted medical claim, even though the administrative remedies for his request for a new cell had been exhausted.”
Is it required that a plaintiff plead and show clearly in his complaint that he has exhausted all administrative remedies?
(Roberts, C.J.) No. A plaintiff is not required to show or argue that he has sought and exhausted all administrative avenues to right his wrong before he approaches the court. The Federal Rules of Civil Procedure do not mention this as a requirement. The list of affirmative defenses in Rule 8(c) is non-exhaustive, so that exhaustion can be another affirmative defense. The Prison Litigation Reform Act is also silent on whether exhaustion is to be used as an affirmative defense by the defendant or pleaded by the plaintiff. This supports the following of usual practice, which means that under the Federal Rules exhaustion is an affirmative defense. Some lower courts do insist that this requirement must be met by the plaintiff, but they are actuated more by the desire to separate frivolous claims from those which have merit. The way to impose a higher standard on pleading, however, is not by varying standards case by case, but by amending the rules.
The PLRA did not state exhaustion had to be pleaded by the inmate, thus evidencing that the usual practice which was to regard exhaustion as an affirmative defense should be followed. The screening requirement did not justify deviating from the usual procedure beyond that in the PLRA. There was no basis to conclude that Congress implicitly transformed exhaustion from an affirmative defense to a pleading requirement by specifying that courts should screen PLRA complaints and dismiss those that failed to state a claim. Section 1997e(g)(1) allowed defendants to waive responses without admitting the allegations notwithstanding any other law or procedural rule, thus showing that when Congress meant to depart from the usual procedure, it did so expressly. Failure to exhaust was an affirmative defense under the PLRA, and inmates were not required to plead exhaustion in their complaints. The rule that each defendant later sued had to have been named in initial grievances lacked a textual basis in the PLRA and prison policy did not specify who a grievance had to name. Dismissal under the total exhaustion rule was error as failure to exhaust one claim did not necessarily affect others.
- Case Brief: 2007
- Petitioner: Lorenzo L. Jones
- Respondent: Barbara Bock, Warden, et al.
- Decided by: Roberts Court
Citation: 549 US 199 (2007)
Granted Mar 6, 2006
Argued: Oct 30, 2006
Decided: Jan 22, 2007