Jones v. Block

549 U.S. 199 (2007)


Exhaustion under the PLRA mandates early judicial screening of prisoner complaints and requires prisoners to exhaust prison grievance procedures before filing suit. Nearly 10 percent of all civil cases filed in federal courts nationwide were prisoner complaints challenging prison conditions or claiming civil rights violations. Most of these cases have no merit; many are frivolous. Congress decided that inmates complaining about prison conditions exhaust prison grievance remedies before initiating a lawsuit. Ps are inmates in the custody of the Michigan Department of Corrections (MDOC). Procedures required that Ps must first attempt to resolve a problem orally within two business days of becoming aware of the issue. A completed grievance form within five business days of the attempted oral resolution could be submitted. Ps may appeal by obtaining an appeal form within five business days of the response and submitting the appeal within five business days of obtaining the form. Another appeal can also be taken. P was involved in a vehicle accident and suffered significant injuries to his neck and back. Several months later Jones was given a work assignment he allegedly could not perform in light of his injuries. The authority made the assignment even though he knew of Jones’s injuries. After unsuccessfully seeking redress through the MDOC’s grievance process, P filed a complaint under 42 U. S. C. §1983 for deliberate indifference to medical needs, retaliation, and harassment. P did not attach copies of the grievance forms or describe the administrative proceedings with specificity. The Judge ruled that P's failure to meet his burden to plead exhaustion in his complaint could not be cured. The Sixth Circuit agreed, holding both that P failed to comply with the specific pleading requirements applied to PLRA suits. P sought review in a petition for certiorari, arguing that the Sixth Circuit’s heightened pleading requirement and total exhaustion rule contravene the clear language of the Federal Rules of Civil Procedure and the PLRA.