The U.S. Supreme Court yesterday, in a 6-3 decision, interpreted the federal Prison Litigation Reform Act to made it harder for prisoners to get into court to challenge their treatment while incarcerated. The case, Woodford v. Ngo (June 22, 2006), involved a complaint by Viet Mike Ngo, who was placed in administrative segregation for "inappropriate activity" in the prison chapel, and later was prohibited from participating in various religious activities, such as confession, Holy Week services and Bible study. Yesterday's Washington Post reported on the decision.
42 USC 1997e(a) requires a prisoner to exhaust "such administrative remedies as are available" before bringing suit in federal court. The majority, in an opinion written by Justice Alito, held that this means that a prisoner who has missed a deadline for filing an administrative remedy is precluded from suing in federal court. Otherwise, they said, a prisoner could ignore the prison's internal grievance system. Chief Justice Roberts and Justices Scalia, Kennedy and Thomas joined the opinion. Justice Breyer wrote a concurring opinion generally agreeing, but saying that the exhaustion principle has some exceptions.
The dissent, written by Justice Stevens, and joined by Justices Souter and Ginsburg, said that all Congress meant was that the prisoner's grievance had to be turned down administratively before he sues. An administrative denial of a prisoner's claim because he failed to comply with some procedural deadline meets the exhaustion requirement and should allow the prisoner to proceed to federal court to vindicate his constitutional rights. The dissenters said that prisoners have little incentive to purposely evade using the prison's internal grievance system before filing suit.
