Pro Se Tips and Tactics: Fourteenth Amendment - Due Process: U. S. Supreme Court Clarifies Some Rights
Pro Se Tips and Tactics: Fourteenth Amendment - Due Process: U. S. Supreme Court Clarifies
by Daniel Manville
For a number of years it seemed that rights of prisoners were being slowly narrowed, if not
eliminated by not only the lower federal courts but also the United States Supreme Court. This
eroding away of rights of prisoners was slowed significantly during the 2004-2005 Supreme
Court term. In that term, the Court made clear the standard for finding the existence of a liberty
interest. Contrary to most lower federal courts, the Court found the existence of a liberty interest
when confined in supermax prisons. The Court also clarified when a prisoner needs to file a writ
of habeas corpus instead of a civil action when the state has changed its parole release
requirements after a prisoner was sentenced.
Muhammad v. Close
Since the late 1990's, confusion existed as to when a prisoner had to obtain a reversal of a guilty
prison misconduct finding prior to bringing a section 1983 action for violation of due process.2
Most lower courts would not authorize a lawsuit concerning facts related to a guilty misconduct
finding until that finding was set aside.3 In Muhammad v. Close, the Supreme Court eliminated
Muhammad filed a lawsuit alleging that prison staff had written a threatening behavior
misconduct report in retaliation for writing grievances and filing prior lawsuits against staff.4 At
the misconduct hearing, Muhammad was found not guilty of the threatening behavior but guilty
of the lesser included offense of insolence.5 In the district court, Muhammad alleged that if he
had been charged with the insolence offense he had actually committed, and not the fabricated
one of threatening behavior, he would not have been placed in segregation pending the
disciplinary hearing.6 He sought damages for the time spent in segregation.7
The district court dismissed the lawsuit for failure to provide sufficient evidence of retaliation.
Muhammad appealed to the Sixth Circuit Court of Appeals. Instead of affirming upon the
grounds found by the district court, the Sixth Circuit applied its earlier holding in Huey v. Stine,8
which held that if a favorable ruling on the prisoner's claims would imply that the disciplinary
guilty finding was wrongfully decided, the prisoner had to have the guilty finding set aside before
the civil rights lawsuit could proceed.9
The Muhammad Court reversed for two reasons. First, it found that the Sixth Circuit had
committed a factual error by assuming that Muhammad had sought expungement of the
insolence guilty finding and the punishment. The Supreme Court stated that nowhere in his
complaint did the prisoner challenge his conviction for insolence or the punishment imposed.10
The second reason for reversing was that the Sixth Circuit erred in applying the favorable
termination rule of Heck to all suits challenging prison disciplinary proceedings.11 The
Supreme Court found that Muhammad's lawsuit did not seek a judgment at odds with his
conviction or with the States calculation of time to be served in accordance with the underlying
sentence.12 Muhammad stated that since no claims were raised in the complaint that would
require the filing of a habeas action, such as seeking return of lost good time or shortening of a
criminal sentence, the favorable termination rule of Heck did not apply.13
Based upon the decision in Muhammad v. Close, the favorable termination rule should be
applied in the following situations:
1. If the prisoner did not lose good time as part of the misconduct guilty proceeding, the
favorable termination rule does not apply, and the prisoner does not have to get the
misconduct conviction overturned in a state forum or by federal habeas corpus prior to bringing
a federal lawsuit. The prisoner can bring a section 1983 lawsuit as soon as prison administrative
remedies are exhausted.
2. If the prisoner did lose good time as a result of the misconduct guilty finding, the favorable
termination rule does apply, so the prisoner cannot bring a section 1983 suit to challenge the
guilty finding until after the misconduct conviction is overturned, either in a state administrative
proceeding, in state court, or by federal habeas corpus after state remedies are exhausted.
3. If the only misconduct punishment imposed is placement in segregation, the favorable
termination rule does not apply. The prisoner can bring a section 1983 lawsuit once the
administrative remedies are exhausted. However, the prisoner will be required to show that the
misconduct conviction deprived him of a liberty interest or imposed an atypical and significant
4. Muhammad does not change the requirements that in all section 1983 lawsuits, the prisoner
has to exhaust available administrative remedies before bringing a section 1983 lawsuit,15 and
is required to show that the misconduct guilty finding deprived the prisoner of a liberty interest
either by imposing an atypical and significant hardship on the prisoner, or by causing the
prisoner to serve more time in prison.16
The Muhammad decision now allows cases to go forward, such as Riley v. Kurtz.17 In 1999, Riley
obtained a jury verdict of $25,003 based largely on the jury finding that prison staff had written
two false misconduct charges to retaliate against Riley. On appeal, the Sixth Circuit reversed the
jury verdict as to the grant of $5,000 in compensatory damages that related to the misconduct
conviction affirmed by the agency, and reduced the damage award to $1,003. Riley argued that
the restrictions imposed in Heck and Edwards were not applicable to him since he had already
served his misconduct punishment and he was serving a life sentence and did not lose any good
time. The Sixth Circuit refused to adopt this argument by Riley in 1999.18 It took another six
years, too late for him, but Riley's argument has finally been adopted by the Muhammad Court.
Two positive things may have developed from Muhammad to assist prisoners in their litigation.
First, appellate courts should not be reluctant, like the Riley panel, to be a step or two ahead of
where the Supreme Court is going. Second, in many cases prisoners can now bring lawsuits for
damages when staff have written false misconducts without first getting the guilty misconduct
findings set aside.
Wilkinson v. Austin
Over the years, prison officials have increased the use of long-term confinement in segregation
for prisoners that they felt were disruptive to the good order of the prison system. These prisons
were given the designation of supermax to reflect the high level of security under which these
disruptive prisoners were confined. In Ohio, prisoners alleged that their initial placement in the
supermax prison denied them due process. Even though on the eve of trial prison officials
changed their supermax placement policy, the district court found that the changes were
inadequate and ordered additional injunctive relief.19 Prison officials appealed to the Sixth
Circuit, which affirmed the finding of a liberty interest. An appeal was then filed with the United
States Supreme Court.
The Supreme Court agreed with the lower courts that there is a liberty interest in staying out of
supermax.20 The Supreme Court stated that although it has held that a liberty interest in
avoiding particular conditions of confinement may arise from state policy or regulation, but in
Sandin21 it abrogated the methodology of parsing the language of particular regulations.22
After Sandin, it is clear that the touchstone of the inquiry into the existence of a protected
state-created liberty interest in avoiding restrictive conditions of confinement is not the language
of regulations regarding those conditions but the nature of those conditions themselves in
relation to the ordinary incidents of prison life.23
This language appears to overrule the decisions of lower courts, including the Sixth Circuit,24
which held that Sandin added a new hurdle (the atypical and significant hardship requirement)
on top of the requirement that prisoners show a liberty interest under the pre-Sandin analysis.25
After Austin, it seems that it is only the conditions of confinement, based upon the regulation,
and not any mandatory language in the regulation, which will determine whether prison
conditions impose an atypical and significant hardship.
The Supreme Court then noted that since Sandin, the circuits have not reached consistent
conclusions for identifying the baseline from which to measure what is atypical and significant
in any particular prison system.26 The Court went on to state that it does not matter in this case
since the supermax imposes an atypical and significant hardship under any plausible
For an inmate placed in OSP [Ohio State Penitentiary], almost all human contact is prohibited,
even to the point that conversation is not permitted from cell to cell; the light, though it may be
dimmed, is on for 24 hours; exercise is for 1 hour per day, but only in a small indoor room. Save
perhaps for the especially severe limitations on all human contact, these conditions likely would
apply to most solitary confinement facilities, but here there are two added components. First is
the duration. Unlike the 30day placement in Sandin, placement at OSP is indefinite and, after an
initial 30day review, is reviewed just annually. Second is that placement disqualifies an otherwise
eligible inmate for parole consideration. While any of these conditions standing alone might not
be sufficient to create a liberty interest, taken together they impose an atypical and significant
hardship within the correctional context.28
The Court found that regardless of the danger that [these] high-risk inmates pose both to
prison officials and other prisoners, this danger does not diminish our conclusion that the
conditions give rise to a liberty interest in their avoidance.29
In determining what process is due under these circumstances, the Austin Court looked to the
factors in Mathews v. Eldridge.30 As to the first factor, the interest involved, the Court stated
that since the prisoners were already lawfully confined, their due process rights were more
limited than where freedom from any confinement was at issue.31
As to Mathews second factor, risk of erroneous placement under Ohio's existing procedures and
the likely value of additional or different safeguards, the Court found that the revised policy of
providing notice of the factual basis for placement, a fair opportunity to offer rebuttal and an
appeal process were sufficient to meet the due process requirements.32
The third factor, the government interest, was a dominant consideration due to prison staffs'
obligation to ensure the safety of others and the threat of gangs. The Court found that the
existence of gangs which are [c]landestine, organized, fueled by racebased hostility, and
committed to fear and violence as a means of disciplining their own members and their rivals,
gangs seek nothing less than to control prison life and to extend their power outside prison
walls, justified the needs of the prison for limited procedures.33 The Court also justified its
decision by referencing the scarce resources of the prison system that are spent to confine
prisoners in supermax and that additional resources would be needed if other procedures were
Austin has now given prisoners a liberty interest in not being placed in long-term segregation if
such placement is of indefinite duration and their eligibility for parole is routinely denied due to
this placement in segregation.35 It is very likely that long term placement in segregation in
Michigan would be found to create a liberty interest since such confinement is of indefinite
duration and parole is routinely denied while a prisoner is confined in segregation.36
Wilkinson v. Dotson
In Wilkinson v. Dotson, the Supreme Court was presented with a challenge to Ohio's parole laws
passed years after Dotson was sentenced, which imposed new procedural requirements as to his
eligibility and suitability for parole. It was claimed that these changes in the parole law violated
the ex post facto clause.37 The district court dismissed the section 1983 actions, holding that
the lawsuit had to be brought as a habeas corpus action.38 On appeal, the Sixth Circuit reversed,
holding that since the claims of the prisoners were related to denial of eligibility and suitability
for parole, and not for release from confinement, section 1983 was the proper action to be filed
rather than an application for habeas corpus.39 The Supreme Court granted review to determine
whether such challenges had to be brought as habeas or civil rights actions.
The Supreme Court stated that its analysis did not depend upon the plaintiff's belief they would
likely be released on parole if the old procedures were applied to their parole review.40 The
Court stated that the lawsuit had to be reviewed to determine whether the remedy sought by the
prisoners would invalidate the duration of their confinement, either directly through an injunction
compelling speedier release, or indirectly through a judicial determination that necessarily implies
the unlawfulness of the States custody.41 If the remedy sought would implicate the length of
the sentence, such as by re-crediting of good time or placement on parole, the prisoners would
be required to bring habeas actions. If the remedy sought would only provide a new review or
hearing in which release could still be denied, the proper remedy would be a civil rights action.
Since the early 1990s many states, including Michigan, have changed the parole review
procedures in relation to prisoners serving long sentences. In almost every state that
implemented these new parole review procedures, the changes have had negative impacts on
those sentenced prior to the enactment of the new law being enacted42 For example, in
Michigan, the issue of ex post facto application of changes in the parole process after sentences
were imposed is presently before the judge in Foster-Bey v. Rubitschun.43 Recently, the Foster-
Bey court, in denying prison official's motion to dismiss, held that the issue of whether the
changes in the parole process violated ex post facto was not ripe for decision, and granted
Defendants argue that the amendments to Michigans parole hearing procedures do not violate
the Ex Post Facto clause. There are two ways that amendments to these procedures can create a
violation: a significant risk may be shown either (1) by [rules] own terms, i.e., on its face, or (2)
the rules practical implementation by the agency charged with exercising discretion . . . .
Garner v. Jones, 529 U.S. at 255. The latter requires the plaintiff to draw on outside evidence.
See, e.g., id. at 256 (requiring the court of appeals to determine whether, as a matter of fact, the
amendment to [the rule] created a significant risk of increased punishment)(emphasis added).
The motion to dismiss presently before the court, however, does not permit the consideration of
this extraneous information. Thus, the issue is not ripe for consideration.44
Ex post facto challenges to changes in the parole review procedures is fact intensive.45 In
reviewing an ex post facto claim alleging adverse changes in parole procedures after the
sentence was imposed, lower courts are to consider (1) whether the changes actually imposed
stricter or discretionary review procedures;46 (2) whether the likelihood of release on parole
decreased after the new parole review procedures were in place47 (3) whether the parole board
retains discretion to hold earlier hearing;48 and (4) whether a full hearing is held or just a file
review. This type of inquiry will involve significant discovery.
The courts have become more hostile to prisoners in the last ten years. Even though the above
decisions have given prisoners a little breathing space in the areas where the worst atrocities are
committed by correctional staff - the writing of false discipline reports to retaliate, the struggle
for justice will continue.49 Congress and the courts have used the filing of frivolous lawsuits by
prisoners to impose draconian restrictions. If you are to have rights that can be litigated, you
must not provide ammunition to those who wish to further curtail your rights. This means that
you must ensure that the lawsuits you file are not frivolous and do not provide more ammunition
to those who care little about your conditions of confinement. You must take these small
victories and build on them by bringing meritorious lawsuits. By ensuring that you file only
lawsuits that are not frivolous, you also ensure that you will be successful in your endeavors. In
this manner you can help ensure that your end result is a victory.
1. This article is a section from The Law of Prisoners Rights, Annual Survey of Michigan Law
2004-5005, Wayne State University Law Review ((to be printed) 2006). It has been modified to
accommodate this audience.
This article is authored by Daniel E. Manville. He is the author and publisher of the recently
released Disciplinary Self-Help Litigation Manual and is currently working on a rewrite of the
Prisoners Self-Help Litigation Manual with John Boston which should be available in late 2006.
Mr. Manville is presently an Adjunct Professor and Clinical Staff Attorney for Wayne State
University Law School Civil Rights Clinic, Detroit, Michigan. Neither the Clinic or Staff Attorney
Manville are able to handle lawsuits in other states.
2. See, e.g., Heck v. Humphrey, 512 U.S. 477, 114 S.Ct. 2364 (1994) (prisoner cannot use § 1983
to obtain relief where success would necessarily demonstrate the invalidity of criminal
conviction); Edwards v. Balisok, 502 U.S. 641, 117 S.Ct. 1584 (1997) (prisoner cannot use § 1983
to obtain relief from misconduct guilty finding where success would necessarily demonstrate the
invalidity of confinement or its duration).
3. See, e.g., Huey v. Stine, 230 F3d 226 (6th Cir. 2000), where the prisoner filed a section 1983
action seeking to challenge a sentence of administrative detention. The Sixth Circuit held that the
favorable termination rule of Edwards v. Balisok, supra, applied even to lawsuits challenging
only the conditions of prison confinement where the relief sought by the prisoner would require
the court to unwind the judgment of the state agency. Id. at 230. The Huey Court used the
favorable termination rule to hold that the prisoner's section 1983 action for violation of his
eighth amendment right failed to state a cognizable claim because to grant the relief he sought
would necessarily have implied that the misconduct conviction was wrongfully obtained. Id.
(Heck generally does not bar eighth amendment claims, but if the claim is founded solely on an
allegation that a corrections officer falsified a disciplinary report, then Heck applies.).
4. 540 U.S. 749, 753, 124 S.Ct. 1303 (2004), on remand, 379 F.3d 413 (6th Cir. 2004).
5. Muhammad, 540 U.S. at 752.
7. Id. at 754.
8. See supra, note 3.
9. See Muhammad, 540 U.S. at 753.
10. Id. at 754.
11. See id. The Muhammad Court stated that its previous rulings limited the favorable
termination ruling to situations where a favorable result from the civil rights action could affect
credits toward release based on good-time served. Id. at 751-52.
12. See Muhammad, 540 U.S at 754-55. Contrary to the Sixth Circuit's statement that
Muhammad had sought expungement of the misconduct charge, the Supreme Court stated that
the Magistrate expressly found or assumed that no good-time credits were eliminated by the
prehearing action. Id
14. See Sandin v. Conner, 515 U.S. 472, 484, 115 S.Ct. 2293 (1995).
15. 42 U.S.C. § 1997e(a); see also Porter v. Nussle, 534 U.S. 516, 531, 122 S. Ct. 983 (2002)
(exhaustion required of all conditions of confinement).
16. See Sandin v. Conner, 515 U.S. at 484 (atypical and significant hardship).
17. 194 F.3d 1313, 1999 WL 801560 (6th Cir. 1999). Author Daniel E. Manville represented Mr.
Riley in both the trial and appellate courts.
18. Id. at **5-6:
We decline to adopt Riley's argument. Even if he has correctly inferred the direction that the
Supreme Court will take in the years to come, the rule he advocates represents a major extension
of what the five justices have actually stated in their various concurring opinions. Unless and
until the Supreme Court adopts the position Riley advocates, we will continue to follow Edwards
and the reasoning of the unpublished Sixth Circuit cases cited above.
19. Austin v. Wilkinson, 189 F. Supp.2d 719 (N.D. Ohio 2002), modified, 204 F. Supp.2d 1024
(2002), affd in part, revd in part, 372 F.3d 346 (6th Cir. 2004), affd in part, revd in part,
Wilkinson v. Austin, U.S. , 125 S.Ct. 2384, 2391 (2005).
20. The State initially conceded this point, but the United States disputed the concession, and
when pressed at oral argument, the State backtracked from its concession. Austin, 125 S.Ct. at
21. Sandin, 515 U.S. at 483-84.
22. Wilkinson, 125 S. Ct. at 2394.
23. Austin, 125 S.Ct. at 2394 (quoting Sandin, 515 U.S. at 484).
24. See, e.g., RimmerBey v. Brown, 62 F.3d 789, 79091 (6th Cir. 1995) (court applied the Sandin
test to the claim of a Michigan inmate that the mandatory language of the MDOCs regulations
created a liberty interest that he receive notice and hearing before being placed in administrative
25. Under pre-Sandin law, a prisoner had to show that the rule, regulation or statute contained
mandatory language and substantive predicates See, e.g., Hewitt v. Helms, 459 U.S. 460,
471-72, 103 S.Ct. 864 (1983) (in determining whether a liberty interest existed, courts were to
ask whether the State had gone beyond issuing mere procedural guidelines but had used
language of an unmistakably mandatory character such that the incursion on liberty would not
occur absent specified substantive predicates.); Washington v. Starke, 855 F.2d 346, 349 (6th
Cir. 1988) (In determining whether stateenacted rules create a protected liberty interest, the key
is whether or not the state has imposed substantive limitations on the discretion of [officers] . .
. or, in other words, whether the state has used language of an unmistakably mandatory
character. The mandatory nature of the regulation is the key, as a plaintiff must have a
legitimate claim of entitlement to the interest, not simply a unilateral expectation of it.).
26. Austin, 125 S.Ct. at 2394 (citations omitted).
27. Id. at 239495.
28. Id. (citation omitted).
29. Id. at 2395.
30. 424 U.S. 319, 335, 96 S.Ct. 893 (1976), where the Court stated that three distinct factors are
First, the private interest that will be affected by the official action; second, the risk of an
erroneous deprivation of such interest through the procedures used, and the probable value, if
any, of additional or substitute procedural safeguards; and finally, the Governments interest,
including the function involved and the fiscal and administrative burdens that the additional or
substitute procedural requirement would entail.
31. Prisoners liberty interest while more than minimal, must be evaluated nontheless, within the
context of the prison system and its attendant curtailment of liberties. Austin, 125 S.Ct. at
32. Id. at 2395-96.
33. Id. at 2396.
34. Id. at 2397.
35. See, e.g., Underwood v. Luoma, 107 Fed. Appx. 543, 544-45, 2004 WL 1859098 (6th Cir.
2004) (unpublished) (placement in administrative segregation for thirteen and a half years does
not constitute an atypical and significant hardship on the inmate); see also Williams v. Vidor, 67
Fed. Appx. 857, 859, 2003 WL 21085362 (6th Cir. 2003) (unpublished) (holding that placement
in administrative segregation for ten years was not an atypical and significant hardship);
Randolph v. Campbell, 25 Fed. Appx. 261, 263, 2001 WL 1580227 (6th Cir. 2001) (unpublished)
(The fact that [ ] administrative segregation placement may have a negative implication on [a
prisoner's parole eligibility] is a collateral consequence of . . . placement in administrative
segregation that is insufficient to create a liberty interest.).
36. See Randolph v. Campbell, id. The court findings that a negative implication on parole
eligibility was not sufficient to create a liberty interest was reversed by Austin.
37. 544 U.S. 74, 125 S.Ct. 1242. 1245 (2005). A due process claim was brought in the lower
court which was not considered by the Supreme Court.
38. Id. at 1245 (Dotson v. Wilkinson, No. 3:00 CV 7303 (N.D. Ohio, Aug. 7, 2000); Johnson v.
Ghee, No. 4:00 CV 1075 (N.D. Ohio, July 16, 2000).).
39. See Dotson v. Wilkinson, 329 F.3d 463 (6th Cir. 2003) (en banc) (procedural challenges to
parole eligibility and parole suitability determinations could appropriately be brought as civil
rights actions under § 1983, rather than pursuant to an application for habeas corpus), affirming
300 F.3d 661 (6th Cir. 2002).
40. See Dotson, 125 S.Ct. at 1247 (In neither case would victory for the prisoners necessarily
have meant immediate release or a shorter period of incarceration; the prisoners attacked only
the wrong procedures, not . . . the wrong result (i.e., [the denial of] goodtime credits). (citations
41. Id. See also California Dept. of Corrections v. Morales, 514 U.S. 499, 506, 115 S.Ct. 1597
(1995) ([T]he focus of the ex post facto inquiry is not on whether a legislative change produces
some ambiguous sort of disadvantage . . . but on whether any such change . . . increases the
penalty by which a crime is punishable).
42. See, e.g., Ali v. Tennessee Bd. of Pardon and Paroles, 431 F.3d 896, 2005 WL 3369877, at
**1 (6th Cir. 2005) (inmate alleged Tennessee Parole Board used regulation enacted after his
conviction to deny parole; district court dismissal of habeas as untimely was reversed); Parker v.
Kelchner, 429 F.3d 58, 64 (3rd Cir. 2005) (inmate alleged violation of ex post facto for denial of
parole based on newly enacted parole statute after inmate was sentencing; writ dismissed on
appeal for failure to exhaust state remedies).
43. No. 05-7138, 2005, WL 2010181, at *7 (E.D. Mich. Aug. 18, 2005).
44. Foster-Bey, 2005 WL 2010181, at *7, Order Granting in Part and Denying in Part
Defendant's Motion to Dismiss. Prisoners alleged that parole board changed second-degree
paroleable life to life means life based upon changes to the parole laws that took effect after
1992 even though they were sentenced prior to that date.
45. See Garner v. Jones, 529 U.S. 244, 120 S.Ct. 1362 (2000) (issue was whether change in
interval from three to eight years for parole reconsideration was an ex post facto violation). The
Supreme Court remanded the case with instruction to allow plaintiff an opportunity to engage in
discovery to show whether the change in the law created a significant increase in punishment.
When the rule does not by its own terms show a significant risk, the respondent must
demonstrate, by evidence drawn from the rules practical implementation by the agency charged
with exercising discretion, that its retroactive application will result in a longer period of
incarceration than under the earlier rule. Id. at 255.
46. See Morales, 514 U.S. at 509 (California amendment changed from an annual review to a
discretionary postponement of up to three years based upon the nature of crimes committed;
Supreme Court stated the changes create[d] only the most speculative and attenuated possibility
of . . . increasing the measure of punishment . . . .).
47. Id. (data showed no change in parole release decisions after new procedures implemented;
about 90% of all prisoners are found unsuitable for parole at the initial hearing, while 85% are
found unsuitable at the second and subsequent hearings. Id., at 510511). See also Shabazz v.
Gabry, 123 F.3d 909, 914 (6th Cir. 1997), cert. denied, 522 U.S. 1120 (1998), the court stated
[w]here amendments to state parole laws postpone initial mandatory parole hearings and
decrease the frequency of subsequent mandatory hearings, but nevertheless provide other viable
opportunities for parole, such amendments do not produce a sufficient risk of increasing the
measure of punishment attached to the covered crimes. The 1992 amendments do not change
the standard for parole, but allow prisoners ample opportunity to petition the Parole Board for
interviews. Further, the 1992 amendments allow the Parole Board to grant parole interviews of its
own volition, and to grant prisoners parole without an interview.
48. Morales, 514 U.S. at 512-13 (in finding no ex post facto violation, the Supreme Court placed
significant reliance on the State's representation that its parole board had a practice of granting
prisoners' requests for early review); Garner, 529 U.S. at 253 ([P]resence of discretion does not
displace the protections of the Ex Post Facto Clause, [as the] danger that legislatures might
disfavor certain persons after the fact is present even in the parole context.).
49. See Woodford v. Ngo, __ U.S. __, 126 S.Ct. 2378 (2006), where Justice Alito imposes his anti-
prisoners views by requiring prisoners to engage in total exhaustion of the prison grievance
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