Woodford v. Ngo
Encyclopedia
Woodford v. Ngo, 548 U.S. 81
(2006), was a United States Supreme Court
case about the procedures determining when prison
litigation
may be commenced in federal court. Justice Samuel Alito
, writing for the majority, ruled that prisoners must exhaust all state-court remedies in accordance with the rules thereof before filing claims in federal court. Justice Stephen Breyer
filed a concurrence. Justice John Paul Stevens
filed a dissent.
(serving a life sentence for murder
,) filed a grievance with California
prison officials about conditions in the prison, but it was rejected as untimely under state law. He then sued the prison officials under §1983
in the Federal District Court.
granted the prison officials' motion to dismiss on the ground that respondent had not fully exhausted his administrative remedies under the PLRA. The Ninth Circuit
Court of Appeals reversed, holding that respondent had exhausted those remedies because none remained available to him. The Supreme Court granted certiorari
.
and Souter
, Stevens writes that "The plain text of the PLRA simply requires that such administrative remedies as are available be exhausted before the prisoner can take the serious step of filing a federal lawsuit against the officials who hold him in custody." He interprets this to mean any exhaustion, not just "proper exhaustion," and says that the Court has read its own interpretation into the statute.
Case citation
Case citation is the system used in many countries to identify the decisions in past court cases, either in special series of books called reporters or law reports, or in a 'neutral' form which will identify a decision wherever it was reported...
(2006), was a United States Supreme Court
Supreme Court of the United States
The Supreme Court of the United States is the highest court in the United States. It has ultimate appellate jurisdiction over all state and federal courts, and original jurisdiction over a small range of cases...
case about the procedures determining when prison
Prison
A prison is a place in which people are physically confined and, usually, deprived of a range of personal freedoms. Imprisonment or incarceration is a legal penalty that may be imposed by the state for the commission of a crime...
litigation
Lawsuit
A lawsuit or "suit in law" is a civil action brought in a court of law in which a plaintiff, a party who claims to have incurred loss as a result of a defendant's actions, demands a legal or equitable remedy. The defendant is required to respond to the plaintiff's complaint...
may be commenced in federal court. Justice Samuel Alito
Samuel Alito
Samuel Anthony Alito, Jr. is an Associate Justice of the U.S. Supreme Court. He was nominated by President George W. Bush and has served on the court since January 31, 2006....
, writing for the majority, ruled that prisoners must exhaust all state-court remedies in accordance with the rules thereof before filing claims in federal court. Justice Stephen Breyer
Stephen Breyer
Stephen Gerald Breyer is an Associate Justice of the U.S. Supreme Court. Appointed by President Bill Clinton in 1994, and known for his pragmatic approach to constitutional law, Breyer is generally associated with the more liberal side of the Court....
filed a concurrence. Justice John Paul Stevens
John Paul Stevens
John Paul Stevens served as an Associate Justice of the Supreme Court of the United States from December 19, 1975 until his retirement on June 29, 2010. At the time of his retirement, he was the oldest member of the Court and the third-longest serving justice in the Court's history...
filed a dissent.
Overview
The Prison Litigation Reform Act of 1995 (PLRA) requires a prisoner to exhaust any available administrative remedies before challenging prison conditions in federal court. Ngo, an inmate at San Quentin State PrisonSan Quentin State Prison
San Quentin State Prison is a California Department of Corrections and Rehabilitation state prison for men in unincorporated San Quentin, Marin County, California, United States. Opened in July 1852, it is the oldest prison in the state. California's only death row for male inmates, the largest...
(serving a life sentence for murder
Murder
Murder is the unlawful killing, with malice aforethought, of another human being, and generally this state of mind distinguishes murder from other forms of unlawful homicide...
,) filed a grievance with California
California
California is a state located on the West Coast of the United States. It is by far the most populous U.S. state, and the third-largest by land area...
prison officials about conditions in the prison, but it was rejected as untimely under state law. He then sued the prison officials under §1983
Civil Rights Act of 1871
The Civil Rights Act of 1871, , enacted April 20, 1871, is a federal law in force in the United States. The Act was originally enacted a few years after the American Civil War, along with the 1870 Force Act. One of the chief reasons for its passage was to protect southern blacks from the Ku Klux...
in the Federal District Court.
Procedural history
The District CourtUnited States District Court for the Northern District of California
The United States District Court for the Northern District of California is the federal United States district court whose jurisdiction comprises following counties of California: Alameda, Contra Costa, Del Norte, Humboldt, Lake, Marin, Mendocino, Monterey, Napa, San Benito, San Francisco, San...
granted the prison officials' motion to dismiss on the ground that respondent had not fully exhausted his administrative remedies under the PLRA. The Ninth Circuit
United States Court of Appeals for the Ninth Circuit
The United States Court of Appeals for the Ninth Circuit is a U.S. federal court with appellate jurisdiction over the district courts in the following districts:* District of Alaska* District of Arizona...
Court of Appeals reversed, holding that respondent had exhausted those remedies because none remained available to him. The Supreme Court granted certiorari
Certiorari
Certiorari is a type of writ seeking judicial review, recognized in U.S., Roman, English, Philippine, and other law. Certiorari is the present passive infinitive of the Latin certiorare...
.
Issue
The question presented was "whether a prisoner can satisfy the Prison Litigation Reform Act's exhaustion requirement ... by filing an untimely or otherwise procedurally defective administrative grievance or appeal."Parties' arguments
The prison officials argued that a prisoner must complete the administrative review process in accordance with the applicable procedural rules, including deadlines, before bringing suit in federal court. Ngo's attorneys, on the other hand, argued that this provision simply means that a prisoner may not bring suit in federal court until administrative remedies are no longer available, even if the reason they are no longer available is due to the prisoner's own non-compliance with the applicable rules.Opinion of the Court
Justice Alito, for the majority, ruled in favor of the prison officials, writing that "proper exhaustion demands compliance with an agency's deadlines and other critical procedural rules because no adjudicative system can function effectively without imposing some orderly structure on the course of its proceedings." The point of the PLRA, he continues, is to avoid "unwarranted federal-court interference with the administration of prisons," and to allow Ngo's interpretation would frustrate the goal of the legislation.Concurrence
Justice Breyer concurred in the judgment. While he agreed with the Court's interpretation of "exhaustion" in this case, he wrote also that administrative law "contains well established exceptions to exhaustion."Dissent
Justice Stevens wrote a dissenting opinion. In that dissent, joined by Justices GinsbergRuth Bader Ginsburg
Ruth Joan Bader Ginsburg is an Associate Justice of the Supreme Court of the United States. Ginsburg was appointed by President Bill Clinton and took the oath of office on August 10, 1993. She is the second female justice and the first Jewish female justice.She is generally viewed as belonging to...
and Souter
David Souter
David Hackett Souter is a former Associate Justice of the Supreme Court of the United States. He served from 1990 until his retirement on June 29, 2009. Appointed by President George H. W. Bush to fill the seat vacated by William J...
, Stevens writes that "The plain text of the PLRA simply requires that such administrative remedies as are available be exhausted before the prisoner can take the serious step of filing a federal lawsuit against the officials who hold him in custody." He interprets this to mean any exhaustion, not just "proper exhaustion," and says that the Court has read its own interpretation into the statute.
See all
External links
- Woodford v. Ngo at supremecourt.gov (docket information)
- full text (HTML with links to precedent, statutes, and U.S. Constitution)