Case law · Highest court · Federal

Porter v. Nussle

Decided
February 26, 2002
Docket
00-853
Status
Published
Jurisdiction
Federal

Cited 4,960 timesNo negative treatment found in this library

What later courts said

  • holding that the exhaustion requirement of the Prison Litigation Reform Act (PLRA) applied to an inmate’s claims that he was beaten by corrections officers without justification — Keith Harbin-Bey v. Lyle Rutter (2005)
  • holding that exhaustion of administrative remedies, pursuant to PLRA, is required for all prisoner suits seeking redress for prison circumstances or occurrences — Carrasquillo v. City of New York (2004)
  • holding that “the PLRA’s exhaustion requirement applies to all inmate suits about prison life, whether they involve general circumstances or particular episodes, and whether they allege excessive force or some other wrong” — Davis v. New York (2002)

Each line is a later court’s own words about this case, not a summary. Read the opinion before relying on it.

How the opinion begins

Justice Ginsburg delivered the opinion of the Court.

This case concerns the obligation of prisoners who claim denial of their federal rights while incarcerated to exhaust prison grievance procedures before seeking judicial relief. Plaintiff-respondent Ronald Nussle, an inmate in a Connecticut prison, brought directly to court, without filing an inmate grievance, a complaint charging that corrections officers singled him out for a severe beating, in violation of the Eighth Amendment’s ban on “cruel and unusual punishments.” Nussle bypassed the grievance procedure despite a provision of the Prison Litigation Reform Act of 1995 (PLRA), 110 Stat. 1321-73, as amended, 42 U. S. C. § 1997e(a) [*520] (1994 ed., Supp. V), that directs: “No action shall be brought with respect to prison conditions under section 1983 of this title, 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.”

The Court of Appeals for the Second Circuit held that §1997e(a) governs only conditions affecting prisoners generally, not single incidents, such as corrections officers’ use of excessive force, actions that immediately affect only particular prisoners. Nussle defends the Second Circuit’s judgment, but urges that the relevant distinction is between excessive force claims, which, he says, need not be pursued administratively, and all other claims, which, he recognizes, must proceed first through the prison grievance process. We reject both readings and hold, in line with the text and purpose of the PLRA, our precedent in point, and the weight of lower court authority, that §1997e(a)’s exhaustion requirement applies to all prisoners seeking redress for prison circumstances or occurrences.

Statutes cited

Cite this

Porter v. Nussle, 534 U.S. 516 (2002)

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