Parole Hearings Are "Prison Conditions" Subject to Exhaustion
Parole Hearings Are "Prison Conditions" Subject to Exhaustion
The U.S. District Court for the Eighth Circuit has held that challenges to parole hearings implicate "prison conditions" and thus are subject to the administrative exhaustion requirements of the Prison Litigation Reform Act (PLRA).
Former Iowa prisoner William Hayden Martin filed suit against the Iowa Board of Parole after the Board denied him parole without allowing Martin to appear in person. Martin alleged in his complaint that he had a constitutional right to be present and sought money damages, and injunctive and declaratory relief.
However, Martin subsequently fully completed his sentence and was discharged in 2008; Martin filed this lawsuit in 2011 while he was incarcerated on an unrelated 10-year sentence.
Defendant then moved to dismiss the case, arguing that Martin did not exhaust his administrative remedies under the PLRA. The district court agreed and dismissed the case.
Martin appealed that decision, but was released on parole from his new sentence less than two years later. Defendant then moved to dismiss the case as moot.
On appeal, the Eighth Circuit found the case moot with respect to injunctive and declaratory relief but not for money damages. The focus then turned to whether a claim relating to parole hearings constituted "prison conditions" subject to the PLRA's administrative exhaustion requirements.
In less than one paragraph, the court concluded that it did, citing to Owens v. Robinson, 356 F. App'x 904 (8th Cir. 2009).
Finding that Martin failed to seek any administrative relief prior to filing his lawsuit, the court held that dismissal was proper.
See: Martin v. State of Iowa, No. 12-3714 (8th Cir. 2014).
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
Related legal cases
Martin v. State of Iowa
| Year | 2014 |
|---|---|
| Cite | No. 12-3714 (8th Cir. 2014) |
| Level | Court of Appeals |
| Conclusion | Bench Verdict |
Owens v. Robinson
| Year | 2009 |
|---|---|
| Cite | 356 F. App'x 904 (8th Cir. 2009) |
| Level | Court of Appeals |
| Conclusion | Bench Verdict |