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Second Circuit: Administrative Remedies Unavailable for Beating at Holding Facility
Loaded on May 5, 2016
published in Prison Legal News
May, 2016, page 34
Filed under:
Guard Brutality/Beatings.
Location:
New York.
The Second Circuit Court of Appeals held the defendants in a civil rights action failed to establish that a prisoner had an available administrative remedy for exhaustion purposes under the Prison Litigation Reform Act (PLRA).
After a New York federal district court granted summary judgment to the defendants, …
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More from this issue:
- Alabama Forced to Confront Criminal Justice Reform, by David Reutter
- Low Pay, Long Hours Fuel Increasing State Prison Staffing Problems, by Derek Gilna
- PLN Exclusive: Illinois Prisoner Exonerated, Released after Ten Years, by Derek Gilna
- How Prison Phone Calls Became a Tax on the Poor
- ACLU Report: Women Uniquely Harmed by Solitary Confinement, by Matthew Clarke
- UK Supreme Court Rules Against Unlawful Use of Solitary Confinement, by Christopher Zoukis
- Disputed PLRA Administrative Exhaustion Issues Properly Resolved in Bench Trial
- $8,000 Settlement for Medical Maltreatment by BOP; Court Finds Experts Not Required, by Derek Gilna
- Corrections Agencies Use Obamacare to Pay for Prisoners’ Medical Care, by Christopher Zoukis
- L.A. County Audit Recommends More Contract Oversight for Probation Department, by Derek Gilna
- Delaware Supreme Court Suspends Prosecutor for Misconduct, by Christopher Zoukis
- $15 Million Award for Prisoner Rendered Paraplegic Due to Medical Malpractice Affirmed, by David Reutter
- Florida’s Private Prison Movement Alive and Well, by David Reutter
- Audits Expose Irregularities in Iowa Prison System Spending, by Derek Gilna
- Seventh Circuit Reverses Dismissal of Ex-prisoner’s § 1983 Action Regarding Computer Disk, by Derek Gilna
- Lawsuit Claims Florida Teen Raped, Beaten in Prison Initiation Ritual
- Fourth Circuit Upholds Denial of Summary Judgment to Guards in Excessive Force Suit
- BOP Pays $70,000 to Settle Lawsuit by Sexually Abused Transgender Prisoner, by Derek Gilna
- $30,000 Settlement for New York Prisoner Assaulted by Guard
- California Supreme Court Rules in Prisoner’s Favor in Compassionate Release Denial, by Gary Hunter
- Nonviolent Michigan Offenders Can Seek Expungement Under New Law, by David Reutter
- Prisoner Rights Advocates Disappointed with Pace of Obama Clemency Initiative, by Derek Gilna
- Former U.S. Attorney General’s Legacy: Too Little, Too Late, by Derek Gilna
- Medically Unacceptable Biopsy States Eighth Amendment Claim
- Prisoners in Chicago Learn Skills, Improve Neighborhoods by Demolishing Vacant Homes, by Gary Hunter
- Report Documents U.S. Recidivism Rates for Federal Prisoners, by Christopher Zoukis
- California Jail’s Psychotropic Medication Policy Leads to Lawsuit, Settlement, by David Reutter
- Idaho Prison Population Drops, Out-of-State Prisoners Re-turned, by Christopher Zoukis
- Delaware Prisoners Sue DOC Alleging Sexual Assaults by Prison Doctor, by Christopher Zoukis
- Seventh Circuit: Former Parolee May Sue Over Delayed Release from Parole
- Hawaii Prisons Experience Security Failures, Other Troubling Incidents, by David Reutter
- Second Circuit: Truth of Arrest Remains Despite Connecticut “Erasure” Law, by Mark Wilson
- Second Circuit: Administrative Remedies Unavailable for Beating at Holding Facility
- BOP Recognizes Humanist Religion after Prisoner Files Suit, by Derek Gilna
- A “Quantum Leap” Isn’t Far Enough for the Prison Phone Industry, by Carrie Wilkinson
- Suit Filed Over New Hampshire DOC’s Restrictive Mail Policy
- Warden’s Decision to Quarantine Handicapped Person in Unaccommodated Cell Actionable; $200,000 Settlement
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- Why is California Thumbing its Nose at a Federal Court?, by Caleb Mason
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- $1,000 Jury Award in Texas Prisoner’s Excessive Use of Force Suit, by Matthew Clarke
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- Supreme Court Reverses SORNA Notification Requirement when Sex Offenders Move Overseas, by Derek Gilna
- Lawsuit Filed Over Death of Pepper-sprayed, Mentally Ill California Prisoner, by Gary Hunter
- From the Editor, by Paul Wright
- News in Brief
More from these topics:
- 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.
- Sixth Circuit Affirms Denial of Qualified Immunity for Michigan Jailer Accused of Retaliatory Assault, Jan. 1, 2026. Retaliation, Guard Brutality/Beatings, Qualified Immunity, 42 U.S. Code § 1983, civil action for deprivation of rights, Deliberate Indifference.
- One Guard Pleads Guilty, Another Receives Light Sentence in New York Prisoner’s Killing, Dec. 1, 2025. Guard Misconduct, Guard Brutality/Beatings, Excessive Force (Wrongful Death), Obstruction of Justice, Plea Agreements/Guilty Pleas.
- Record $42.75 Million Verdict in Louisiana Detainee’s Death in LaSalle Jail, Dec. 1, 2025. Guard Brutality/Beatings, Pepper Spray/Tear Gas, Contractor Liability, Failure to Train/Supervise, Deliberate Indifference.
- New Jersey Breaks Ground on New $330 Million Women’s Prison After Raid at Old Facility, Dec. 1, 2025. Staff-Prisoner Assault, Guard Misconduct, Prosecutor/Attorney General Misconduct, Guard Brutality/Beatings, Prison Rape Elimination Act.
- California’s Attorney General Is Suing Los Angeles County Jails Over “Inhumane Conditions”, Nov. 1, 2025. Jail Misconduct, Totality of Conditions, Food, Overcrowding, Exposure to Cold, Plumbing, Sewage, Sanitation, Hygiene Supplies, Vermin, Exposure to Heat, Guard Brutality/Beatings, Complaints, Consent Decrees, Failure to Treat (Mental Illness).
- $950,000 Awarded to Trans Maryland Prisoner Dropped on Her Face by Guards, Nov. 1, 2025. Guard Misconduct, DOC/BOP misconduct, Government Misconduct, Retaliation for Filing Grievances, Retaliation for Organizing, Retaliatory Segregation, Guard Brutality/Beatings, Restraints, Discrimination (Transgender), Failure to Protect (Transgender), Immunity - Absolute and Qualified, Damages - Compensatory, Wrongful Use of Force.

