Jones v. Bock

549 U.S. 199, 127 S. Ct. 910, 166 L. Ed. 2d 798, 2007 U.S. LEXIS 1325
CourtSupreme Court of the United States
DecidedJanuary 22, 2007
Docket05-7058
StatusPublished
Cited by9,953 cases

This text of 549 U.S. 199 (Jones v. Bock) is published on Counsel Stack Legal Research, covering Supreme Court of the United States primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

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Jones v. Bock, 549 U.S. 199, 127 S. Ct. 910, 166 L. Ed. 2d 798, 2007 U.S. LEXIS 1325 (2007).

Opinion

Chief Justice Roberts

delivered the opinion of the Court.

In an effort to address the large number of prisoner complaints filed in federal court, Congress enacted the Prison Litigation Reform Act of 1995 (PLRA), 110 Stat. 1321-71, as amended, 42 U. S. C. § 1997e et seq. Among other reforms, the PLRA mandates early judicial screening of prisoner complaints and requires prisoners to exhaust prison grievance procedures before filing suit. 28 U. S. C. § 1915A; 42 U. S. C. § 1997e(a). The Sixth Circuit, along with some other lower courts, adopted several procedural rules designed to imple *203 ment this exhaustion requirement and facilitate early judicial screening. These rules require a prisoner to allege and demonstrate exhaustion in his complaint, permit suit only against defendants who were identified by the prisoner in his grievance, and require courts to dismiss the entire action if the prisoner fails to satisfy the exhaustion requirement as to any single claim in his complaint. Other lower courts declined to adopt such rules. We granted certiorari to resolve the conflict and now conclude that these rules are not required by the PLRA, and that crafting and imposing them exceeds the proper limits on the judicial role.

I

Prisoner litigation continues to “account for an outsized share of filings” in federal district courts. Woodford v. Ngo, 548 U. S. 81, 94, n. 4 (2006). In 2005, nearly 10 percent of all civil cases filed in federal courts nationwide were prisoner complaints challenging prison conditions or claiming civil rights violations. 1 Most of these cases have no merit; many are frivolous. Our legal system, however, remains committed to guaranteeing that prisoner claims of illegal conduct by their custodians are fairly handled according to law. The challenge lies in ensuring that the flood of nonmeritorious claims does not submerge and effectively preclude consideration of the allegations with merit. See Neitzke v. Williams, 490 U. S. 319, 327 (1989).

Congress addressed that challenge in the PLRA. What this country needs, Congress decided, is fewer and better prisoner suits. See Porter v. Nussle, 534 U. S. 516, 524 (2002) (PLRA intended to “reduce the quantity and improve *204 the quality of prisoner suits”). To that end, Congress enacted a variety of reforms designed to filter out the bad claims and facilitate consideration of the good. Key among these was the requirement that inmates complaining about prison conditions exhaust prison grievance remedies before initiating a lawsuit.

The exhaustion provision of the PLRA states:

“No action shall be brought with respect to prison conditions under [42 U. S. C. § 1983], or any other Federal law, by a prisoner confined in any jail, prison, or other correctional facility until such administrative remedies as are available are exhausted.” 42 U. S. C. § 1997e(a).

Requiring exhaustion allows prison officials an opportunity to resolve disputes concerning the exercise of their responsibilities before being haled into court. This has the potential to reduce the number of inmate suits, and also to improve the quality of suits that are filed by producing a useful administrative record. Woodford, supra, at 94-95. In an attempt to implement the exhaustion requirement, some lower courts have imposed procedural rules that have become the subject of varying levels of disagreement among the federal courts of appeals.

The first question presented centers on a conflict over whether exhaustion under the PLRA is a pleading requirement the prisoner must satisfy in his complaint or an affirmative defense the defendant must plead and prove. 2 The *205 Sixth Circuit, adopting the former view, requires prisoners to attach proof of exhaustion — typically copies of the grievances — to their complaints to avoid dismissal. If no written record of the grievance is available, the inmate must plead with specificity how and when he exhausted the grievance procedures. Knuckles El v. Toombs, 215 F. 3d 640, 642 (2000).

The next issue concerns how courts determine whether a prisoner has properly exhausted administrative remedies— specifically, the level of detail required in a grievance to put the prison and individual officials on notice of the claim. The Sixth Circuit requires that a prisoner have identified, in the first step of the grievance process, each individual later named in the lawsuit to properly exhaust administrative remedies. Burton v. Jones, 321 F. 3d 569, 575 (2003). Other Circuits have taken varying approaches to this question, see, e. g., Butler v. Adams, 397 F. 3d 1181, 1183 (CA9 2005) (proper exhaustion requires use of the administrative process provided by the State; if that process does not require identification of specific persons, neither does the PLRA); Johnson v. Johnson, 385 F. 3d 503, 522 (CA5 2004) (“[T]he grievance must provide administrators with a fair opportunity under the circumstances to address the problem that will later form the basis of the suit”); Riccardo v. Rausch, 375 F. 3d 521, 524 (CA7 2004) (exhaustion satisfied if grievance “served its function of alerting the state and inviting corrective action”), none going as far as the Sixth Circuit in requiring in every case that the defendants have been named from the beginning of the grievance process.

Finally, the Circuits are divided over what the PLRA requires when both exhausted and unexhausted claims are in- *206 eluded in a complaint. 3 Some Circuits, including the Sixth Circuit, apply a “total exhaustion” rule, under which no part of the suit may proceed if any single claim in the action is not properly exhausted. See, e. g., Jones Bey v. Johnson, 407 F. 3d 801, 805 (CA6 2005). Among Circuits requiring total exhaustion there is further disagreement over what to do if the requirement is not met. Most courts allow the prisoner to amend his complaint to include only exhausted claims, e. g., Kozohorsky v. Harmon, 332 F.

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Bluebook (online)
549 U.S. 199, 127 S. Ct. 910, 166 L. Ed. 2d 798, 2007 U.S. LEXIS 1325, Counsel Stack Legal Research, https://law.counselstack.com/opinion/jones-v-bock-scotus-2007.