United States Supreme Court

In a 42 U.S.C. section 1983 suit by a state prisoner against two prison guard who allegedly assaulted him during transfer, the Fourth Circuit's reversal of the District Court's dismissal of the suit, holding that 'special circumstances' can excuse a failure to comply with administrative procedural requirements, particularly where the inmate reasonably, even though mistakenly, believed he had sufficiently exhausted his remedies, is vacated and remanded where: 1) the Fourth Circuit's unwritten 'special circumstances' exception is inconsistent with the text and history of the Prison Litigation Reform Act of 1995 (PLRA); and 2) plaintiff's contention that the prison's grievance process was not in fact available to him warrants further consideration below.

Appellate Information

• Published 2016/06/06

Judges

• KAGAN

Court

• United States Supreme Court

Counsel