BOOTH – Appellant
Versus
CHURNER et al. , (2001) – Respondent
The Prison Litigation Reform Act of 1995 amended 42 U. S. C. §1997e(a), which now requires a prisoner to exhaust "such administrative remedies as are available" before suing over prison conditions. Petitioner Booth was a Pennsylvania state prison inmate when he began this 42 U. S. C. §1983 action in Federal District Court, claiming that respondent corrections officers violated his Eighth Amendment right to be free from cruel and unusual punishment by assaulting him, using excessive force against him, and denying him medical attention to treat ensuing injuries. He sought various forms of injunctive relief and money damages. At the time, Pennsylvania provided an administrative grievance and appeals system, which addressed Booths complaints but had no provision for recovery of money damages. Before resorting to federal court, Booth filed an administrative grievance, but did not seek administrative review after the prison authority denied relief. Booths failure to appeal administratively led the District Court to dismiss the complaint without prejudice for failure to exhaust administrative remedies under §1997e(a). The Third Circuit affirmed, rejecting Booths argument that the exhaustion requirement is inapposite to his case because the administrative process could not award him the monetary relief he sought (money then being the only relief still requested).
Held: Under 42 U. S. C. §1997e(a), an inmate seeking only money damages must complete any prison administrative process capable of addressing the inmates complaint and providing some form of relief, even if the process does not make specific provision for monetary relief. The meaning of the phrase "administrative remedies ... available" is the crux of the case. Neither the practical considerations urged by the parties nor their reliance on the dictionary meanings of the words "remedies" and "available" are conclusive in seeking congressional intent. Clearer clues are found in two considerations. First, the broader statutory context in which Congress referred to "available" "remedies" indicates that exhaustion is required regardless of the relief offered through administrative procedures. While the modifier "available" requires the possibility of some relief for the action complained of, the word "exhausted" has a decidedly procedural emphasis. It makes no sense, for instance, to demand that someone exhaust "such administrative [redress]" as is available; one "exhausts" processes, not forms of relief, and the statute provides that one must. Second, statutory history confirms the suggestion that Congress meant to require procedural exhaustion regardless of the fit between a prisoners prayer for relief and the administrative remedies possible. Before §1997e(a) was amended by the 1995 Act, a court had discretion (though no obligation) to require a state inmate to exhaust "such ... remedies as are available," but only if they were "plain, speedy, and effective." That scheme is now a thing of the past, for the amendments eliminated both the discretion to dispense with administrative exhaustion and the condition that the remedy be "plain, speedy, and effective" before exhaustion could be required. The significance of deleting that condition is apparent in light of McCarthy v. Madigan,
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