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Ninth Circuit: California Prisoner Need Not Appeal from Satisfactory Grievance Response in Order to Exhaust Administrative Remedies
Loaded on Oct. 15, 2011
by Michael Brodheim
published in Prison Legal News
October, 2011, page 21
Clarifying “the boundaries of proper exhaustion” within the context of California’s prison system, the Ninth Circuit Court of Appeals held that a prisoner “has no obligation to appeal from a grant of relief, or a partial grant that satisfies him, in order to exhaust administrative remedies.”
Filed under:
Disciplinary Litigation,
Disciplinary Appeals,
Prompt Hearings,
PLRA,
Administrative Exhaustion (PLRA),
Appeals,
Limitations.
Location:
California.
In July 2004, Quillie …
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More from this issue:
- The Failed Promise of Prison Privatization, by Richard Culp, Ph.D.
- From the Editor, by Paul Wright
- FDOC Pen Pal Advertising Ban Passes Constitutional Scrutiny, by David Reutter
- Human Rights Defense Center Litigation Update, by Lance Weber
- Economy Forces States to Rethink Juvenile Justice Policies, Priorities
- California’s Behavior Modification Programs – Abuse of Prisoners, Racism and Cover-Ups
- D.C. District Court Partially Dismisses Lawsuit by BOP CMU Prisoners
- Ninth Circuit: California Prisoner Need Not Appeal from Satisfactory Grievance Response in Order to Exhaust Administrative Remedies, by Michael Brodheim
- Massachusetts Prisoners Receive Expired Food Rejected by Schools
- Tennessee Jail Detainee Shackled During Childbirth Awarded $200,000
- California District Court Rips Feds for “False and Misleading Information” in FOIA Case, Then Does Nothing
- California Inspector General Expresses Concerns About Out-of-State Private Prisons
- Oregon Aggravated Murder Statute Creates Liberty Interest, by Mark Wilson
- FBI Claims 2,500 Percent Increase in Child Porn Arrests
- Montana Jail Agrees to Provide Addiction Treatment for Pregnant Prisoners
- Pennsylvania Councilman Takes Private Prison Company’s Donation, then Opposes Detention Center
- $10,000 Settlement in North Carolina Prisoner’s Pepper Spraying
- Department of Justice Report on Sexual Victimization in Prisons and Jails
- Los Angeles County Pays $400,000 to Settle Juvenile Jail Prisoner Wrongful Death Suit
- 90% Remittitur of $750,000 Strip Search Verdict Vacated; Plaintiffs Accept $440,385.08 on Remand, by Mark Wilson
- Postcard-Only Mail Policy Enjoined at Colorado Jail
- Prisons Are Breeding Ground for Terrorists?, by Mark Wilson
- Former Florida Prison Guard Sues for Reinstatement Under Whistleblower Act
- Prison Legal News Sues Arizona Jail Over Restrictive Mail Policy
- Budget Cuts Threaten Oregon Juvenile Offenders
- Congressional Budget Resolution Cuts Some DOJ Programs
- Fugitive Oregon DOC Food Manager Getting Homesick in Iran
- Oregon Juvenile Who Attempted Suicide Settles Negligence Suit for $192,500
- Sexual Misconduct Topples Two Oregon Prosecutors
- Taser International Settles Product Liability Lawsuit for $2.85 Million, by Michael Brodheim
- U.S. Supreme Court: State P&A Can Sue Another State Agency for Records, by David Reutter
- PLN Sues Kansas Jail Over No-Publication Policy
- Jail Guitar Doors, USA Offers Free Musical Instruments to Prisons, by Bruce Reilly
- Florida’s Prison Industry Criticized for Failing in Mission, by David Reutter
- Oregon Prison Guard Guilty of Contraband Smuggling
- Report Finds Federal Prisoners Exposed to Toxic Metals in Recycling Jobs
- ICE, CCA Settle ACLU Lawsuit Regarding Health Care for Immigration Detainees, by Derek Gilna
- Sixth Circuit: Prisoner Must be Allowed Direct Appeal When Prison Delayed Appeal Mailings, by Matthew Clarke
- CCA Psychiatrist’s License Restricted for Sexual Misconduct with Florida Female Prisoners
- Louisiana Sex Offender Agrees to Surgical Castration, by David Reutter
- CORRECTIONS To Danny Trejo Interview in August 2011 PLN
- News In Brief:
More from Michael Brodheim:
- California: Prisoner Not Entitled to Points Reduction in Classification Score Unless Actually Participating in Programs, Aug. 24, 2016
- CDCR Adopts New Contraband Rules on Obscene, Gang-related Materials, July 7, 2015
- Arizona Department of Corrections Adopts Same-Sex Marriage Policy, July 7, 2015
- California Prison Officials Ordered to Provide Qualified Sign Language Interpreters for All Deaf Prisoners, July 7, 2015
- Plata Court Authorizes Force-Feeding of Hunger-Striking California Prisoners, July 2, 2015
- June, 2013 Proves To Be Deadly Month for California Prisoners, June 12, 2015
- California: Commission Recommends Reforms for Jail Overcrowding, Sentencing, June 12, 2015
- Nevada Jail Charges Prisoners for Meals, Medical Care to Defray Costs, June 3, 2015
- Pennsylvania Jail Guard Who Assaulted Prisoner Gets Home Confinement, Probation, June 3, 2015
- California Pays $585,000 to Settle Suit by Prisoner Who Lost Eye Due to Poor Medical Care, May 6, 2015
More from these topics:
- 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).
- Ohio Supreme Court Awards Prisoner $1,000 for Denied Records Request, April 1, 2026. Administrative Exhaustion (PLRA), Damages, Public Records, Public Records Act.
- Sixth Circuit Announces State-Law Exceptions to Appeal Deadlines Preserve “Pending” Status Under AEDPA, Holding Belated-Appeal Procedures Toll Federal Habeas Limitations Period, April 1, 2026. Limitations, Habeas Corpus, AEDPA, Appealable Issues/Orders, Failure to Address/Advise Defendant.
- 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.
- Eleventh Circuit Upholds Dismissal of Six Female Alabama Jail Detainees’ Sexual Assault Suit, Jan. 1, 2026. Jail Misconduct, Summary Judgment, Limitations, Municipal Liability, Criminal Sexual Abuse.
- U.S. District Court in Arizona Grants Summary Judgment in Favor of Prisoner Denial of Forms for Challenging 455 Days of Solitary, Jan. 1, 2026. Totality of Conditions, Administrative Exhaustion (PLRA), Control Units/SHU/Solitary Confinement, Chemical Spraying of Mentally Ill Inmates, Deliberate Indifference.
- Ninth Circuit Grants Equitable Tolling Under AEDPA Where Attorney Abandoned Prisoner by Failing to Communicate for Nine Months and Prison Officials Delayed Processing Filing Documents, Dec. 15, 2025. Attorney Misconduct, Legal Materials, Law Library Access/Adequacy, Limitations, AEDPA.
- Second Circuit Vacates Finding that Prisoner Failed to Exhaust Administrative Remedies; Remands Conditions of Confinement and Due Process Claims, Dec. 1, 2025. Totality of Conditions, Failure to Protect (General), Administrative Exhaustion (PLRA), Municipal Liability, Ad-Seg Hearings.
- Eighth Circuit: Former Prisoner’s Amended Complaint Filed After Release Not Subject to PLRA Exhaustion Requirement, Dec. 1, 2025. Failure to Treat, Administrative Exhaustion (PLRA), Complaints, Cruel and Unusual Punishment, Deliberate Indifference.
- Wisconsin Prisoner Wins in Seventh Circuit Review of Exhaustive Remedies Case, Dec. 1, 2025. Failure to Treat, Failure to Protect (General), Administrative Exhaustion (PLRA), Grievances, Jury Trial.

