Jones v. Bock & Williams v. Overton (consolidated)
Jones and Williams are both prisoners who sued prison employees for better treatment. Jones complained that the prison was deliberately indifferent to his serious medical needs in violation of the Eighth Amendment because it forced him to perform tasks that aggravated his injuries from a car accident. Williams claimed violations of the Americans with Disabilities Act, the Rehabilitation Act, and the Eighth and Fourteenth Amendments when the prison denied his requests for surgery and a private room because of his disfigured arm.
A district court dismissed both prisoners’ complaints for failing to exhaust administrative remedies as required by the Prison Litigation Reform Act of 1995, which requires prisoners to file administrative grievances before filing a complaint in court. On appeal, the United States Court of Appeals for the Sixth Circuit upheld the district court rulings. The court held that Jones failed to prove exhaustion because he did not attach his previous grievances to his complaint or explain the outcome of those grievances. Williams did not meet the exhaustion requirement because he named defendants in his court case who were not specifically named in his grievance for a private room; thus, he had not exhausted all of his claims against those individuals. Additionally, the court dismissed the medical claim because it follows the “total exhaustion” rule, which requires the dismissal of all of the claims if the plaintiff has even a single unexhausted claim.
Questions Presented:
(1) Whether satisfaction of the Prison Litigation Reform Act’s exhaustion requirement is a prerequisite to a prisoner’s federal civil rights suit such that the prisoner must allege in his complaint how he exhausted his administrative remedies (or attach proof of exhaustion to the complaint), or alternatively, whether non-exhaustion is an affirmative defense that must be pleaded and proven by the defense?
(2) Whether the PLRA requires a prisoner to name a particular defendant in his or her administrative grievance in order to exhaust his or her administrative remedies as to that defendant and to preserve his or her right to sue them?
(3) Whether the PLRA prescribes a “total exhaustion” rule that requires a federal district court to dismiss a prisoner’s federal civil rights
complaint for failure to exhaust administrative remedies whenever there is a single unexhausted claim, despite the presence of other exhausted
aims?
Decisions under Review:
Jones v. Bock
Williams v. Overton
