The US Supreme Court [official website] ruled [opinion, PDF] Monday in Ross v. Blake [SCOTUSblog materials] that an inmate could not file a court challenge against a prison guard without exhausting all administrative remedies. The question before the court was whether there is a “special circumstances” exception under the Prison Litigation Reform Act (PLRA) [text], which requires inmates to exhaust all administrative remedies, when the inmate erroneously believed that he satisfied this requirement by participating in an internal investigation. In an opinion by Justice Elena Kagan, the Supreme Court held that there is no such exception:
The [PLRA] mandates that an inmate exhaust “such administrative remedies as are available” before bringing suit to challenge prison conditions. The court below adopted an unwritten “special circumstances” exception to that provision, permitting some prisoners to pursue litigation even when they have failed to exhaust available administrative remedies. Today, we reject that freewheeling approach to exhaustion as inconsistent with the PLRA.
Justice Clarence Thomas filed an opinion concurring in part and concurring in the judgment. Justice Stephen Breyer filed an opinion concurring in part.
The case arose after prison inmate Shaidon Blake sued Lieutenants Michael Ross and James Madigan for excessive use of force. The officers filed an amended answer to the complaint alleging that Blake had not exhausted all administrative remedies available as the PLRA required. The US Court of Appeals for the Fourth Circuit reversed [opinion, PDF] the lower court decision and held that the “special circumstances” exception to the PLRA’s exhaustion requirement was met. The court stated that the internal investigation provided prison official ample time to address Blake’s complaints and Blake believed he had exhausted all administrative remedies, thus meeting the “special circumstances” exception. The court heard oral arguments in the case in March after granting certiorari [JURIST reports] in December.