Jones v. Bock (2006)
- Docket
- 05-7058
- Decided
- 2006-01-01
Summary
Question: 1) Does the Prisoner Litigation and Reform Act require that a prisoner bringing a federal civil rights suit show how he exhausted his administrative remedies before suing, rather than requiring that the defense prove that the administrative remedies were not exhausted? 2) Does the Prisoner Litigation and Reform Act require a court to dismiss a prisoner's civil rights suit for failure to exhaust administrative remedies whenever there is a single unexhausted claim, despite the presence of other exhausted claims? From Williams v. Overton : 3) Does the Prisoner Litigation Reform Act require that a prisoner name a particular defendant in his administrative grievance in order to exhaust his administrative remedies as to that defendant and preserve his right to sue? Conclusion: No to all. The Court ruled unanimously that the Sixth Circuit's rules for exhaustion of administrative remedies were not required by the Prisoner Litigation Reform Act. The opinion by Chief Justice John Roberts held that prisoners bring civil rights lawsuits do not need to demonstrate that they have already exhausted all administrative remedies. The Sixth Circuit had assumed that Congress had intended to put the burden on the plaintiff, but the Court ruled that an explicit statement by Congress would have been required. The Justices also held that when a court is presented with a suit with both exhausted and unexhausted claims, the court can let the exhausted claims proceed rather than dismissing the entire suit. The Court rejected the argument that the statute's use of the word "action" instead of "claim" indicated that the entire suit should be dismissed. The opinion explained that Congress was merely using "boilerplate language." Finally, the Court ruled that the PLRA did not require a prisoner to name each defendant in his administrative grievance in order to name the defendant in his subsequent lawsuit. By imposing these extraneous rules, the Sixth Circuit had exceeded its legitimate authority over the management of its docket.