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PLRA Administrative Remedy Exhaustion Requirement Not Retroactive

The Second Circuit has held that the Exhaustion of Administrative Remedies requirement of the Prison Litigation Reform Act (PLRA), 42 U.S.C. § 1997e(a), does not apply to suits pending prior to the PLRA's enactment.

Abdullah Y. Salahuddin, a New York state prisoner, filed a civil rights suit under 42 U.S.C. ...

 

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