×
You've used up your 3 free articles for this month. Subscribe today.
Sixth Circuit Requires Total Exhaustion Under PLRA; Decision Conflicts with Hartsfield
Loaded on April 15, 2006
published in Prison Legal News
April, 2006, page 39
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 …
Full article and associated cases available to subscribers.
As a digital subscriber to Prison Legal News, you can access full text and downloads for this and other premium content.
Already a subscriber? Login
More from this issue:
- Georgia Prisons: A Blight On The Peach State, by Michael Rigby
- Texas Counties Set To Raid State Prisoners Trust Fund Accounts
- From the Editor, by Paul Wright
- Colorado DOC s Medical Oversight Found Remiss, by G.A. Bowers
- CSC Pays Public Defender Social Worker $125,000 for Rape in Juvenile Facility
- Former Georgia Parole Chairman Loses Appeal of Corruption Conviction
- Weary California Prison Gang Members Increasingly Opt Out for Solace of Sensitive Needs Yards
- Cell-Block Beatdown: Do Boston Prisoners Have Any Chance of Holding Abusive Prison Guards Responsible? Signs Are Not Promising, by David S. Bernstein
- Continued Reliance on Commitment Offense to Deny California Lifers Parole Denies Federal Due Proces, by Marvin Mentor
- Petty Stone Cold Kickbacks KO Government Employees Nationwide
- PHS Pays $350,000 to Settle Claim for Over-Medication Death of Florida Jail Prisoner
- Dismissal of Medical and Retaliation Claims Reversed, by Bob Williams
- Georgia Legislature Awards Wrongly Convicted Man $1 Million
- Minnesota County Settles Suit over Untreated Appendicitis for $225,000
- State Auditor Blasts Colorado DOC's Private Prison Oversight Failures, by Matthew T. Clarke
- Phoenix, Arizona, Settles Krone Wrongful Imprisonment Suit for $3 Million
- California DOC Settles Racially Determinative Housing Suit, by John Dannenberg
- Michigan Jails Strip Policy Unconstitutional; Guards and Get Qualified Immunity, County Liable, by David Reutter
- Severely Beaten L.A. County Jail Prisoner Wins Only $5,000
- Californias 2005 Prison Suicide Rate Doubles Over 2004, by John Dannenberg
- Utah Jail Policy Banning Subscriptions to Magazines and Newspapers Enjoined; Fees Awarded, by John Dannenberg
- Alabama Work Release Prisoners Reclassified Following Escapes
- NYDOCS Abandons ADA DOJ Exhaustion Defense
- Eighth Circuit Upholds Denial of Compensatory/Punitive Damages; Physical
- Exhaustion Not Required in Pennsylvania Parole Denial Challenges
- New York Prisoner Awarded $2,250 For Wrong Medication
- Repercussions from Georgia Courthouse Escape, Shootings Continue
- L.A. County Jail Gets $20,000 from State for Pruno-Sniffing Dogs; Inmate Welfare Funds Tapped to Mai
- $1.1 Million FTCA Emotional Distress Award In BOP Suicide Death Upheld, Even Though Murder By Guar
- Alabama Diabetic Prisoner Stomped On and Retaliated Against by Guard Awarded $20,000, by John Dannenberg
- Ohio Man Awarded $618,000 for Nearly 16 Years Wrongful Imprisonment
- PLRA Doesnt Bar FRCP 15(a) Amendment of Complaint - No HIV/Hepatitis Treatment = Imminent Danger o
- PLRA Doesnt Alter FRCP 23 Class Certification Analysis
- No Qualified Immunity on Toothpaste, Inhaler & Ventilation Claims
- Appointment of Counsel Satisfies Access to Courts Requirement
- Seventh Circuit Reverses Jail Lockdown Dismissal; Day After Christmas = Legal Holiday
- Missouri's 5-Year Limitation Period Applies to § 1983 Claims; 8th Circuit Reverses Earlier Decision to Contrary
- $1,250 Settlement in Oregon Retaliation, Court Access Claims
- Washington Prison Staff Properly Fired For Sexually Assaulting Prisoner
- On Remand From Supreme Court, Sixth Circuit Reverses Judgment on Guard Retaliation Claim
- Any Reliance On AA or NA Participation During Parole Consideration Violates Establishment Clause, by John Dannenberg
- Dismissal of Bivens Action for Non-Exhaustion Reversed
- California Probationers and Parolees Not Similarly Situated As To Eligibility For Prop. 36 Drug Tr, by John Dannenberg
- Sixth Circuit Requires Total Exhaustion Under PLRA; Decision Conflicts with Hartsfield
- Fair Labor Standards Acts Minimum Wage Provision Not Applicable to Private Prisons
- Washington Appeals Court Reverses the Dismissal of a Slip-and-Fall Negligence Action; State Responsi
- 2nd Circuit Reverses Sua Sponte § 1915 Dismissal; Parolee Owed Duty of Habitable Residence
- News in Brief
- Prisoner Suit Alleging Sexual Assault By Colorado Sheriffs Staff Reinstated
More from these topics:
- Atlanta Jail Boasts Improvements Since Consent Decree, Reports from Monitor and ACLU Are More Critical, May 1, 2026. Staffing, Sanitation, Guard Brutality/Beatings, Consent Decrees, Bail/Pretrial Release.
- Texas Officials Testify That Cost to Air Condition Prisons Tops $1.5 Billion, May 1, 2026. Eighth Amendment, Exposure to Heat, Administrative Exhaustion (PLRA), Deliberate Indifference, Prison Litigation Reform Act (PLRA).
- Six Maryland Guards Convicted in Prisoner’s Beating, Cover-up; § 1983 Suit Filed, May 1, 2026. Guard Brutality/Beatings, 42 U.S. Code § 1983, civil action for deprivation of rights, Obstruction of Justice, Wrongful Use of Force, Evidence - Destruction/Fabrication/Manipulation of.
- Judge Denies New York Prison Chief’s Motion to be Dismissed from Case Related to Robert Brooks’ Murder, May 1, 2026. Work Strikes, Guard Brutality/Beatings, Failure to Train/Supervise, Police--Excessive Force, Deliberate Indifference.
- Ohio Supreme Court Awards Prisoner $1,000 for Denied Records Request, April 1, 2026. Administrative Exhaustion (PLRA), Damages, Public Records, Public Records Act.
- Eleventh Circuit: District Court Erred in Dismissing BOP Prisoner’s Medical Claim, Finds Prison Officials Made Administrative Remedies Unavailable, March 1, 2026. Systemic Medical Neglect, OB/GYN, Failure to Treat, Administrative Exhaustion (PLRA), Deliberate Indifference.
- Sixth Circuit Revives Michigan Prisoner’s Challenge to Guard Tackle That Broke His Foot, March 1, 2026. Evidentiary Ruling (Disciplinary Hearings), Guard Brutality/Beatings, Summary Judgment, Qualified Immunity, Wrongful Use of Force.
- Differing Judicial Outcomes for the New York Guards Who Killed Robert Brooks, Feb. 1, 2026. Guard Misconduct, Guard Brutality/Beatings, Failure to Protect (Wrongful Death), Excessive Force (Wrongful Death), Pending Appeal/Sentencing.
- The New York Prison System’s Culture of Cruelty and Impunity, Feb. 1, 2026. Guard Misconduct, Racial Discrimination, Guard Brutality/Beatings, Restraints, Excessive Force (Wrongful Death).
- $404,000 Verdict for Ohio Prisoner Brutalized by Trio of Guards, Kept in Solitary for Two Years, Jan. 1, 2026. Retaliation for Filing Grievances, Retaliatory Segregation, Guard Brutality/Beatings, Pepper Spray/Tear Gas, Control Units/SHU/Solitary Confinement.

