Supreme Court Decision Overturns Draconian Limitations on Prisoner Litigation Imposed by the Sixth Circuit

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Today the Supreme Court Unanimously Overturned a Sixth Circuit Decision that Barred Most Prisoners from Asserting their Constitutional Rights

WASHINGTON — The American Civil Liberties Union today welcomed a unanimous Supreme Court decision striking down a series of barriers to prisoner litigation imposed by the Sixth Circuit. Today’s decision in Jones v. Bock overturned the strict requirements imposed by the Sixth Circuit in the provision of the Prison Litigation Reform Act (PLRA) that mandates that prisoners “exhaust” administrative remedies.

“This was a critical decision for prisoners whose rights have been violated,” said Elizabeth Alexander, Director of the ACLU National Prison Project, which filed a friend of the court brief in the case that was cited in today’s ruling. “The Sixth Circuit rules were so draconian that they barred almost all claims from prisoners without counsel.”

The PLRA, a law passed in 1996 and claimed to be directed at frivolous lawsuits filed by prisoners, requires a prisoner to complete an internal prison grievance process before filing a lawsuit in federal court. In the Jones v. Bock decision by the Sixth Circuit, additional restrictions were imposed that required prisoners to:

• Name all defendants in their grievances in order to file a lawsuit against them. If prisoners failed to do so, they could not sue the persons not mentioned in their grievances.
• Prove that they exhausted all administrative remedies through the grievance process before filing a lawsuit in federal court.
• Exhaust all remedies on every issue in the lawsuit. Prisoners who failed to exhaust on one of several issues raised in the suit would have their entire cases dismissed.

Today’s Supreme Court ruling overturned those requirements, stating that they go too far. In the decision, Chief Justice Roberts wrote that the Sixth Circuit’s exhaustion rules are not required by the PLRA and that “imposing them exceeds the proper limits on the judicial role.” The Court unanimously agreed that if a prisoner fails to exhaust administrative remedies on some of his grievances, but not all, then only those parts that had not been addressed should be dismissed. The Court also agreed that prisoner lawsuits should not be thrown out simply because the prisoner had failed to show exhaustion in the court filing. Finally, the Court stated that a prisoner does not have to list all defendants in the grievance process in order to sue them in federal court. The decision cited the friend-of-the-court brief filed by the ACLU, which pointed out that most prison grievance procedures do not require prisoners to identify specific individuals.

“The PLRA severely limits prisoners’ access to federal courts. Today’s decision will at least help to ensure that the courthouse door is not completely shut for prisoners who have been denied basic rights and have nowhere else to turn,” said Steven Shapiro, Legal Director of the ACLU.

The Jones v. Bock decision is online at: www.aclu.org/scotus/2006term/
jonesv.bockwilliamsv.overton/28105lgl20070122.html

The ACLU’s brief in the case is online at: www.aclu.org/scotus/2006term/26789res20060919/26789res20060919.
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