Ross v. Blake (578 U.S. 632)

U.S. Supreme Court · decided June 6, 2016 · Supreme Court Database (Spaeth)

Citation
578 U.S. 632 · 136 S. Ct. 1850
Decided
June 6, 2016
Term
October Term 2015
Vote
8–0
Majority author
Justice Kagan
Issue area
Civil Rights
Disposition
Vacated and remanded
Outcome
Petitioning party won
Ideological direction
Conservative

Opinion excerpt

Justice KAGAN delivered the opinion of the Court. The Prison Litigation Reform Act of 1995 (PLRA) mandates that an inmate exhaust "such administrative remedies as are available" before bringing suit to challenge prison conditions. 42 U.S.C. § 1997e(a). 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. But we also underscore that statute's built-in exception to the exhaustion requirement: A prisoner need not exhaust remedies if they are not "available." The briefs and other submissions filed in this case suggest the possibility that the aggrieved inmate lacked an available administrative remedy. That issue remains open for consideration on remand, in light of the principles stated below. I Respondent Shaidon Blake is an inmate in a Maryland prison. On June 21, 2007, two guards-James Madigan and petitioner Michael Ross-undertook to move him from his regular cell to the facility's segregation unit. According to Blake's version of the facts, Ross handcuffed him and held him by the arm as they left the cell; Madigan followed close behind. Near the top of a flight of stairs, Madigan shoved Blake in the back. Ross told Madigan he had…

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