LOCATION:United States District Court Eastern District of Michigan
DOCKET NO.: 00-853
DECIDED BY: Rehnquist Court (1986-2005)
LOWER COURT: United States Court of Appeals for the Second Circuit
CITATION: 534 US 516 (2002)
ARGUED: Jan 14, 2002
DECIDED: Feb 26, 2002
Irving L. Gornstein – Assistant to the Solicitor General, argued the cause for the United States, as amicus curiae, by special leave of court, supporti
John R. Williams – Argued the cause for the respondent
Richard Blumenthal – Hartford, Connecticut, argued the cause for the petitioners
Facts of the case
In 1999, Ronald Nussle, an inmate at the Cheshire Correctional Institution in Connecticut, filed a federal action under 42 USC section 1983, charging that certain correction officers had subjected him to a sustained pattern of harassment and intimidation and had singled him out for a severe beating in violation of the Eighth Amendment. In doing so, Nussle did not file a grievance under the applicable Connecticut Department of Correction procedures. Based on the Prison Litigation Reform Act of 1995 (PLRA), the District Court dismissed the suit, finding that PLRA directs that “No action shall be brought with respect to prison conditions under section 1983…or any other Federal law, by a prisoner…until such administrative remedies as are available are exhausted.” In reversing, the Court of Appeals held that exhaustion of administrative remedies is not required for a claim of the kind Nussle asserted. Citing legislative history, the appellate court found that the phrase “prisons conditions” covers only conditions affecting prisoners generally, not single incidents that immediately affect only particular prisoners.
Does the Prison Litigation Reform Act of 1995 require that all prisoners seeking redress for prison circumstances or occurrences exhaust any applicable administrative remedies before filing suit?
Media for Porter v. Nussle
Audio Transcription for Opinion Announcement – February 26, 2002 in Porter v. Nussle
William H. Rehnquist:
The opinion of the Court No. 00-853 Porter against Nussle will be announced by Justice Ginsburg.
Ruth Bader Ginsburg:
This case concerns prisoners who claim denial of their federal rights while incarcerated and their obligation to exhaust prison grievance procedures before seeking relief in court.
Ronald Nussle, an inmate in Connecticut prison, brought directly to court without filing an inmate grievance a complaint charging that corrections officers singled him out for a severe beating in violation of the Eighth Amendment stand on cruel and unusual punishment.
Nussle bypassed the grievance procedure despite a provision of The Prison Litigation Reform Act requiring inmates to exhaust administratively all claims with respect to prison conditions before filing suit.
The Court of Appeals for the Second Circuit agreed with Nussle that the Act exhaustion provision did not apply to his complaint.
The provision’s key words “prison condition” the Court held cover only complaints about conditions affecting prisoners generally not complaints about single-incident.
Nussle defends the Second Circuit’s judgment but urges that the relevant distinction is between excessive force claims which he says need not be pursued administratively in all other claims which he recognizes must proceed first to the prison grievance process.
We reject both readings and reverse to Second Circuit judgment.
Our decisional guides are The Prison Litigation Reform Act text and context and our prior opinions interpreting similar statutory language.
The pathmarking case is McCarthy against Bronson.
The statute we interpreted in that case authorizes district judges to refer to magistrate judges prisoner petitions, challenging conditions of confinement.
The petitioning prisoner in McCarthy argued that the provision governing referrals to magistrate judges covered claims about ongoing prison conditions not complaints like his that homed in on an isolated incident of excessive force.
Finding nothing to suggest that Congress meant to divide prisoner’s petition to this subcategories, we rejected the prisoner’s argument.
The phrase “Prisoner petitions challenging conditions of confinement”, we held in McCarthy, applies broadly to all claims about occurrences or circumstances in prison including complaints targeting general conditions as well as complaints about isolated incident of excessive force.
McCarthy was a 1991 decision; Congress enacted The Prison Litigation Reform Act in 1995.
Our normal presumption is that Congress expects its statutes to be read in line with our precedent.
That presumption the Prison Litigation Reform Act’s dominant concern to promote administrative redress, to filter out groundless claims, and to foster better prepared litigational claims that are aired in court persuade us that the exhaustion provision’s key word “prison conditions” are properly read through McCarthy’s lens.
We are fortified in reading the statute as we do by this overriding consideration.
Scant sense supports the Second Circuit’s single occurrence prevailing circumstances dichotomy.
Why should a prisoner have immediate access to Court when a guard assaults him on one occasion, as the Second Circuit held, but not when beatings are widespread or routine.
The distinction Nussle urges between excessive force claims on the one hand and all other suits arising in prison on the other presents a similar anomaly.
Do prison authorities have an interest in receiving prompt notice of, and an opportunity to take action against guard brutality that is somehow less urgent than their interest in receiving notice and an opportunity to stop other types of staff wrongdoing?
Isn’t that answer plainly no?
In sum, we hold that The Prison Litigation Reform Act exhaustion requirement applies to all inmate suits about prison life whether they involve general circumstances or particular episodes and whether they allege excessive force or some other wrong.
The decision is unanimous.