The barriers the lower court had put in place “cannot fairly be viewed” as a correct interpretation of the law, the Prison Litigation Reform Act of 1995, Chief Justice John G. Roberts Jr. said for the court. Unless Congress explicitly provided otherwise, Chief Justice Roberts explained, courts should apply to prisoners’ lawsuits the same procedural rules they apply to any other lawsuit and “should generally not depart from the usual practice under the federal rules on the basis of perceived policy concerns.”
The ruling was greeted with relief by advocates for prisoners’ rights, who said the lower court’s approach had threatened to make it all but impossible for an inmate not represented by a lawyer to navigate the procedural hurdles to get a case accepted for a hearing.
“A loss would have been devastating,” said Elizabeth Alexander, director of the National Prison Project of the American Civil Liberties Union, which filed a brief in support of three Michigan inmates whose separate cases were consolidated by the court for a single decision. Dismissed by the United States Court of Appeals for the Sixth Circuit, their complaints about their treatment are now reinstated.
Ms. Alexander said the decision, Jones v. Bock, No. 05-7058, marked the first time in a half-dozen rulings that the Supreme Court had not adopted the most unfavorable possible interpretation of the Prison Litigation Reform Act.
At issue was the Sixth Circuit’s interpretation of the law. The appeals court, which covers Ohio, Kentucky and Tennessee as well as Michigan, adopted three rules to carry out the law’s requirement that before going to federal court with a complaint about prison conditions, an inmate must first “exhaust” any administrative remedies provided by the prison.
First, the appeals court held, this requirement meant that inmates had to prove they had exhausted their remedies, in contrast to the ordinary federal rule that places on the defendant the burden of showing, as a defense, that the plaintiff had failed to meet an exhaustion requirement. Second, prisoners could not sue anyone they had not first named during the internal grievance process. And third, a lawsuit that contained a mixture of exhausted and unexhausted claims should be dismissed in its entirety.
In his opinion on Monday, Chief Justice Roberts said “we understand the reasons” for the Sixth Circuit’s approach. He noted that prisoners’ lawsuits accounted for nearly 10 percent of all civil cases filed in federal court and that many were without merit.
But he added that the circuit’s choice of its “more onerous pleading rules” was not based on the statute. “The judge’s job is to construe the statute — not to make it better,” he said.