S.Ct. Prisoner Court Access Case
Keywords
The Supreme Court reversed a Sixth Circuit decision that placed judicial roadblocks on the filing of prisoner litigation above and beyond statutory provisions and federal rules. The Prison Litigation Reform Act of 1995 (PLRA) established new, additional requirements for exhaustion of administrative remedies and quick review of the sufficiency of prisoners’ claims prior to the filing of an answer. The Sixth Circuit went above and beyond the PLRA and the usual rules for the sufficiency of a complaint in dismissing prisoner litigation. The Supreme Court stated that the Sixth Circuit’s decisions were based on policy considerations that were outside the bounds of the judicial role. The court also noted that the exhaustion requirements were not required to state a claim under 42 U.S.C. § 1983. Jones v. Bock, 2007 WL 135890 (Jan. 22, 2007). The unanimous decision was written by Chief Justice Roberts.
The Supreme Court decision reviewed 3 separate cases in which the Sixth Circuit completely dismissed cases filed by prisoners. In one, an injured prisoner was forced to work at a job that aggravated his injuries, even though prison officials who assigned him to the job knew of his injuries. In a second case, an inmate was denied surgery that could provide pain relief by prison officials who viewed the surgery as cosmetic. In the third case, a black inmate alleged that his punishment for assaulting a guard was more severe than the punishment for the same infraction allotted to two white prisoners.
The first procedural issue addressed by the court is whether the complaint must plead and prove in the complaint that administrative remedies had been exhausted. The plaintiff had in fact exhausted his administrative remedies, but he did not attach copies of the grievance forms to the complaint or describe the proceedings with specificity. The Supreme Court held that the Sixth Circuit’s dismissal was unwarranted. The Court acknowledged that the PLRA intended to reduce prisoner litigation by making exhaustion mandatory, but the Court agreed with the majority of circuit courts that prisoners simply had to include a short and plain statement of the claim in the complaint, as required by the federal rules. The Court stated: “The PLRA itself is not a source of a prisoner’s claim; claims covered by the PLRA are typically brought under 42 U.S.C. § 1983, which does not require exhaustion at all.” The Court explained that the usual practice is that exhaustion is an affirmative defense and not a heightened pleading standard. The Court emphasized that “courts should generally not depart from the usual practice under the Federal Rules on the basis of perceived policy concerns.” The Court refused to imply this heightened standard based on other procedural requirements in the PLRA, noting that “when Congress meant to depart from the usual procedural requirements, it did so expressly.” The Court found that the imposition of a pleading requirement “cannot fairly be viewed as an interpretation of the PLRA,” and cited Justice Frankfurter for the proposition that “the judge’s job is to construe the statute-not to make it better.”
The second procedural issue was whether the suits should be dismissed on the grounds that the administrative grievances did not identify each and every defendant who was later sued. Once again the Supreme Court held that the Sixth Circuit’s judicially created rule that prisoners name all defendants in their grievance “lacks a textual basis in the PLRA.” The Court held that “exhaustion is not per se inadequate simply because an individual later sued was not named in the grievances.”
The third issue was whether the Sixth Circuit improperly dismissed an entire suit when only some but not all claims were fully exhausted. The Supreme Court noted that the Sixth Circuit did have some textual support for its dismissal in the PLRA, which states that “no action shall be brought” unless administrative procedures are exhausted. However, in other contexts, “statutory references to an ‘action’ have not typically been read to mean that every claim included in the action must meet the pertinent requirement before the ‘action’ may proceed.” The Court rejected the policy considerations that dismissal would reduce the burden of prisoner litigation on the courts. The Court noted that the complete dismissal of a case in which not all claims were exhausted would only lead to repeated filing of claims or the filing of various claims in separate suits. The Court stated: “the debate about consequences is close enough that there is no clear reason to depart from the more typical claim-by-claim approach.”
While the Supreme Court went out of its way to indicate support for the closing of the court house doors to prisoners who did not exhaust administrative remedies as required by the PLRA, the Court nevertheless refused to allow the Sixth Circuit to go above and beyond statutory requirements and ordinary federal procedure in the pursuit of reducing prisoner litigation.