OCTOBER TERM, 2005
WOODFORD V. NGO
SUPREME COURT OF THE UNITED STATES
WOODFORD et al. v. NGO
certiorari to the united states court of appeals for the ninth circuit
No. 05–416. Argued March 22, 2006—Decided June 22, 2006
The Prison Litigation Reform Act of 1995 (PLRA) requires a prisoner to exhaust any available administrative remedies before challenging prison conditions in federal court. 42 U. S. C. §1997e(a). Respondent filed a grievance with California prison officials about his prison conditions, but it was rejected as untimely under state law. He subsequently sued petitioner officials under §1983 in the Federal District Court, which granted petitioners’ motion to dismiss on the ground that respondent had not fully exhausted his administrative remedies under §1997e(a). Reversing, the Ninth Circuit held that respondent had exhausted those remedies because none remained available to him.
Held: The PLRA’s exhaustion requirement requires proper exhaustion of administrative remedies. Pp. 5–21.
(a) Petitioners claim that a prisoner must complete the administrative review process in accordance with applicable procedural rules, including deadlines, as a precondition to bringing suit in federal court, but respondent contends that §1997e(a) allows suit once administrative remedies are no longer available, regardless of the reason. To determine the correct interpretation, the Court looks for guidance to both administrative and habeas corpus law, where exhaustion is an important doctrine. Administrative law requires proper exhaustion of administrative remedies, which “means using all steps that the agency holds out, and doing so properly.” Pozo v. McCaughtry, 286 F. 3d 1022, 1024. Habeas law has substantively similar rules, though its terminology is different. Pp. 5–11.
(b) Given this background, the Court is persuaded that the PLRA requires proper exhaustion. Pp. 11–17..
(1) By referring to “such administrative remedies as are available,” §1997e(a)’s text strongly suggests “exhausted” means what it means in administrative law. P. 11..
(2) Construing §1997e(a) to require proper exhaustion also serves the PLRA’s goals. It gives prisoners an effective incentive to make full use of the prison grievance process, thus providing prisons with a fair opportunity to correct their own errors. It reduces the quantity of prisoner suits. And it improves the quality of those suits that are filed because proper exhaustion often results in creation of an administrative record helpful to the court. In contrast, respondent’s interpretation would make the PLRA’s exhaustion scheme totally ineffective, since exhaustion’s benefits can be realized only if the prison grievance system is given a fair opportunity to consider the grievance. That cannot happen unless the grievant complies with the system’s critical procedural rules. Respondent’s arguments that his interpretation would filter out frivolous claims are unpersuasive. Pp. 11–14..
(3) As interpreted by respondent, the PLRA exhaustion requirement would be unprecedented. No statute or case purports to require exhaustion while at the same time allowing a party to bypass deliberately the administrative process by flouting the agency’s procedural rules. None of his models is apt. He first suggests that the PLRA requirement was patterned on habeas law as it existed between 1963 and 1977 when, under Fay v. Noia, 372 U. S. 391, 438, a federal habeas claim could be procedurally defaulted only if the prisoner deliberately bypassed state remedies. That would be fanciful, however. The PLRA was enacted contemporaneously with the Antiterrorism and Effective Death Penalty Act of 1996, which gave federal habeas review a structure markedly different from what existed before 1977. Furthermore, respondent’s interpretation would not duplicate that scheme, for it would permit a prisoner to bypass deliberately administrative review with no risk of sanction. Respondent next suggests that the PLRA exhaustion requirement is patterned on §14(b) of the Age Discrimination in Employment Act of 1967 and §706(e) of Title VII of the Civil Rights Act of 1964, but neither provision is in any sense an exhaustion provision. Pp. 14–17.
(c) Respondent’s remaining arguments regarding §1997e(a)’s interpretation are also unconvincing. Pp. 17–21.
403 F. 3d 620, reversed and remanded.
Alito, J., delivered the opinion of the Court, in which Roberts, C.J., and Scalia, Kennedy, and Thomas, JJ., joined. Breyer, J., filed an opinion concurring in the judgment. Stevens, J., filed a dissenting opinion, in which Souter and Ginsburg, JJ., joined.