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Sixth Circuit Requires Total Exhaustion Under PLRA; Decision Conflicts with Hartsfield

A panel of the Sixth Circuit joined the Eighth and Tenth Circuits in holding that the Prison Litigation Reform Act (PLRA) requires total exhaustion. One judge dissented, however, criticizing the majority opinion as being invalid for conflicting with Hartsfield v. Vidor, 199 F.3d 305 (6th Cir. 1999).

Lamar William Jones ...

 

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