Woodford v. Ngo

PETITIONER: Jeanne S. Woodford et al.
RESPONDENT: Viet Mike Ngo
LOCATION: Board of Immigration Appeals

DOCKET NO.: 05-416
DECIDED BY: Roberts Court (2006-2009)
LOWER COURT: United States Court of Appeals for the Ninth Circuit

CITATION: 548 US 81 (2006)
GRANTED: Nov 14, 2005
ARGUED: Mar 22, 2006
DECIDED: Jun 22, 2006

ADVOCATES:
Dan Himmelfarb - argued the cause for Petitioners
Jennifer G. Perkell - argued the cause for Petitioners
Meir Feder - argued the cause for Respondent

Facts of the case

Under the Prison Litigation Reform Act of 1995 (PLRA), prisoners must exhaust any available administrative remedies for resolving disputes within the prison system before they can bring suit in federal court. Viet Mike Ngo filed a grievance with the California prison system, but it was dismissed because he had waited too long to file it. He then brought suit in federal district court. California objected, arguing that he had not exhausted his administrative remedies, and that the fact those remedies were no longer available to him because of his delay in filing was immaterial. The district court agreed, but the Ninth Circuit Court of Appeals reversed, finding that all of Ngo's administrative remedies were "exhausted" because they were no longer available to him.

Question

Does a prisoner satisfy the Prison Litigation Reform Act of 1995's requirement that he exhaust all administrative remedies available to him before bringing suit in federal court by filing an untimely or otherwise procedurally defective administrative grievance which is rejected?

Media for Woodford v. Ngo

Audio Transcription for Oral Argument - March 22, 2006 in Woodford v. Ngo

Audio Transcription for Opinion Announcement - June 22, 2006 in Woodford v. Ngo

John G. Roberts, Jr.:

Justice Alito has the opinion in 05-416, Woodford versus Ngo.

Samuel A. Alito, Jr.:

This case comes to us on writ of certiorari to the United States Court of Appeals for the 9th Circuit.

Petitioners are California prison officials, and respondent is a prisoner who was in their custody.

In October of 2000, respondent was placed in administrative segregation for alleged misconduct in the San Quentin Prison chapel.

Two months later, he was returned to the general population; but he claims that he was excluded from participating in a variety of religious activities.

Respondent filed a challenge to this exclusion under California’s administrative prison grievance system six months later.

California law gives prisoners 15 working days to file such a grievance, and respondent’s grievance accordingly was rejected as untimely.

After unsuccessfully appealing that decision internally, respondent filed the underlying lawsuit against petitioners in Federal District Court.

The District Court dismissed respondent’s suit for failing to exhaust administrative remedies, as required by the exhaustion provision of the Prison Litigation Reform Act, the PLRA.

Respondent appealed and the 9th Circuit reversed, holding that respondent had exhausted administrative remedies, because no such remedies were any longer available.

This decision was consistent with the decision of the 6th Circuit, but conflicted with decisions of four other Courts of Appeals.

We granted certiorari and now reverse.

The PLRA states that a prisoner may not bring an action with respect to prison conditions until such administrative remedies as are available are exhausted.

We hold that this means that a prisoner must properly exhaust administrative remedies, which includes compliance with time limits.

The PLRA refers to administrative remedies, and in administrative law, the general rule is that courts should not topple over administrative decisions unless the administrative body not only has erred, but has erred against objection made at the time appropriate under its practice.

That is the United States versus Tucker Truck Lines.

This doctrine serves several purposes: it gives agencies a fair opportunity to fix their own mistakes before being held into federal court, and it discourages disregard of agency procedures; it also promotes efficiency, as meritorious claims are often settled at the administrative level, and a loss at that level may convince a party not to seek a remedy in federal court.

Because exhaustion requirements are designed to deal with parties who may not want to exhaust their administrative remedies, administrative law creates an incentive for parties to give the agency a fair opportunity to consider their claims.

Administrative law does this by requiring proper exhaustion as a condition for going to federal court.

The reason for requiring proper exhaustion is straightforward: no adjudicative system can function effectively if parties are free to disregard its procedural rules.

The law of habeas corpus also requires proper exhaustion, but it uses different terminology.

The text and general scheme of the PLRA show that the Act adopts the administrative-law concept of proper exhaustion.

The Act was intended to reduce the quantity and improve the quality of prisoner litigation, and proper exhaustion is needed to serve these ends.

Proper exhaustion gives state officials an adequate opportunity to consider and resolve meritorious claims, and it creates a record for a subsequent review of claims that cannot be resolved.

The interpretation urged by respondent would thwart the purposes of the PLRA.

It would permit prisoners to deliberately bypass prison grievance systems, and respondent has not identified any statute or case that allows this.

We are confident that Congress did not create such an ineffectual scheme here.

We reverse the judgment of the Court of Appeals for the 9th Circuit and remand the case for proceedings consistent with this opinion.

Justice Breyer has filed an opinion concurring in the judgment; Justice Stevens has filed a dissent, in which Justices Souter and Ginsburg join.