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Eleventh Circuit Says Georgia Prisoner Failed to Exhaust Remedies by Filing Late Grievance to Ask for Investigation that Was Already Underway
by David M. Reutter
Here’s a simple message to prisonersfrom the U.S. Court of Appeals for the Eleventh Circuit: Exhaust your remedies, no matter how redundant they may seem.
That was the key takeaway from the Court’s ruling on August 31, 2021, in which it held that …
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More from this issue:
- PrimeCare: Less Medical Care for Prisoners, Higher Expenses for Taxpayers, More Profits for Corporate Owner, by Matthew Clarke
- Vermont Supreme Court: Removing Prisoner From Programming Is Reviewable When Catalyst Was Punitive
- From the Editor, by Paul Wright
- $11 Million Settlement Reached in Tennessee Suit Alleging False Arrest and False Imprisonment of Minors, by Edward Lyon
- Nine Deaths in Three Years at CoreCivic Jail in Florida, None From COVID-19
- $5.5 Million Settlement to California Prisoner Left Incapacitated After Suicide Attempt at Santa Cruz County Jail, by Edward Lyon
- Pittsburgh Jail Records 13 Deaths in Two Years, Only One From COVID-19, by Jo Ellen Nott
- California Federal Court Approves Consent Decree Upgrading Mental Health Care at Alameda County Jail, by David Reutter
- Trapped in The Floods: With Floodwaters Rising, Prisoners Wait for Help in Floating Feces, by Alleen Brown
- Fifth BOP Staffer Arrested in “Rape Club” at California Federal Prison, by Jo Ellen Nott
- Eighth Circuit Rules Pretrial Detainees and Prisoners Have Right to Visit Family Members
- Tenth Circuit Says Parolee May Not be Forced to Participate in Religious Program Under Threat of Jail, by David Reutter
- $8.5 Million Paid by Pennsylvania DOC for Death of Asthmatic Prisoner Improperly Pepper-Sprayed, by Matthew Clarke
- Investigation Finds Hundreds of Unreported Deaths in Tennessee Prisons and Jails, by Harold Hempstead
- $260,000 in Attorney Fees Awarded by California Federal Court after Finding Governing State Law Not Impacted by PLRA, by David Reutter
- Multiple Florida DOC Guards Convicted of Assault, Smuggling and Child Sex Abuse, by Jo Ellen Nott
- Hawaii Supreme Court Orders New Parole Hearing for Prisoner Held Since 1979, by Douglas Ankney
- $2.2 Million Settlement Over Transgender Georgia Prisoner’s Suicide Is Largest in State DOC History, by Matthew Clarke
- Eleventh Circuit Says Georgia Prisoner Failed to Exhaust Remedies by Filing Late Grievance to Ask for Investigation that Was Already Underway, by David Reutter
- Nevada Federal Court Denies Motion to Compel Arbitration by Rapid Financial Solutions in Debit Card Suit, by David Reutter
- $6,500 Paid by Nevada DOC After Ninth Circuit Affirms Denial of Qualified Immunity for Withholding Evidence From Prisoner Accused of Smuggling Meth in Mail, by David Reutter
- Ecuador’s Prison System in Catastrophic Crisis, by Edward Lyon
- What to Know about Using Pell Grants to Take College Classes in Prison, by Richard Hahn
- $725,000 Settlement Reached in North Carolina Prisoner’s Suicide at Troubled Jail, by Keith Sanders
- $316,673 Settlement in New Mexico Prisoner’s Lawsuit Over Stabbing at GEO-Operated Private Prison, by Matthew Clarke
- Guard Arrested for Running “Fight Club” in New Jersey Prison Kitchen, by Ashleigh Dye, Jayson Hawkins
- Tenth Circuit Says Disabled Colorado Prisoner Offered Diapers Rather Than Bathroom Pass May Deserve Damages Under ADA, by David Reutter
- Sweetheart Deal Nets GEO Group $15 Million Payout from ICE for Haitian Deportation Flights, by Ashleigh Dye
- Ninth Circuit Says Nevada DOC Not Micromanaged by Requirement to Treat Prisoner’s Severe Mental Illness; Upholds Preliminary Injunction, by Matthew Clarke
- Con Who Conned Cons is Sentenced to Federal Prison
- Absenteeism Skyrockets for New York City Jail Guards, Up 215% Over the Last Two Years, by Jo Ellen Nott
- DOJ Reaches Settlement Over Disability Access With Vermont Prison System, by Jacob Barrett
- Ninth Circuit: Error to Instruct Jury to Defer to Medical Staff’s Asserted Security Justification for Terminating California Prisoner’s Morphine Prescription Without Tapering, by Matthew Clarke
- Preliminary Injunction Granted to Illinois Prisoner to Receive Non-Allergenic Kosher Meals, by David Reutter
- Connecticut Supreme Court Rules That Prisoner Was Denied Due Process with Sex Offender Classification, by Harold Hempstead
- Lifting Six-Year Moratorium, Oklahoma Treats Witnesses to Convulsing and Vomiting Prisoner During Execution, by Keith Sanders
- Washington State Supreme Court Holds that Denying Wheelchair-Bound Prisoner Access to Water and Toilet Facilities Violates State Constitution, by Douglas Ankney
- News in Brief
- HRDC Sues New Hampshire Jail over Publications Banned under No-Hard-Copy Mail Policy, by Sam Rutherford
- HRDC Sues Nebraska Department of Correctional Services for Banning its Books, by Sam Rutherford
More from David Reutter:
- Eight Circuit Reverses Denial of Partial Qualified Immunity in Detainee’s Pepper Ball Claim, Remands Excessive Force Claims, Sept. 1, 2026
- Nevada Prisoners, Families Call Out Predatory Tablet Program, Sept. 1, 2026
- Fourth Circuit: Error in Granting Judgment Prior to Adjudging Spoliation Motion, Sept. 1, 2026
- Fourth Circuit Affirms Qualified Immunity in Strip Searches Resulting from Anonymous Tips, Sept. 1, 2026
- Tenth Circuit: Colorado Governor Unentitled to Eleventh Amendment Immunity on Claim Related to DOC Religious Policies, Aug. 1, 2026
- Michigan Appeals Court: Witnesses Cannot be Forced to Wear Jail Clothes at Trial, Aug. 1, 2026
- Sixth Circuit Affirms Denial of State-Law Qualified Immunity in Scabies Case, Aug. 1, 2026
- Fourth Circuit Revives Disabled Prisoner’s Claim for Denial of Out-of-Cell Exercise Time, Aug. 1, 2026
- 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
- Florida Supreme Court Announces Rule 3.170(f)’s Good-Cause Plea-Withdrawal Standard Does Not Apply at Post-Appeal Resentencing, April 1, 2026
More from these topics:
- Delaware’s Lack of Prison Healthcare Oversight, Sept. 1, 2026. Contractor Misconduct, Corrections Audits, Systemic Medical Neglect, Private Contractors, Grievances.
- Formally Available, Rarely Granted: A State Prisoner’s Guide to Federal Habeas Relief, Sept. 1, 2026. Administrative Exhaustion, Habeas Corpus, Bureau of Prisons Orders, Administrative Law/Remedies, Evidence - Integrity/Reliability of, Tolling of Statutes of Limitations and Laches, Federal Rules of Evidence, Statute of Limitations.
- Fifth Circuit Upholds Dismissal of Suit by Civilly Committed Texan, Dec. 1, 2025. Sex Offenders (Discrimination), Conditions of Confinement, Complaints, Grievances, Civil Commitment.
- 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.
- Sixth Circuit Holds Dismissal Not Automatic When Plaintiff Simultaneously Files Same Claims in State Court, Aug. 1, 2025. Retaliation, Court Access, Grievances, Mail.
- Ninth Circuit: Continuing-Violations Doctrine Applies for PLRA Administrative Exhaustion Purposes, Aug. 1, 2025. Failure to Protect (General), Administrative Exhaustion (PLRA), Grievances, Prison Litigation Reform Act (PLRA).
- Ninth Circuit Revives Prisoner’s Claim Based on Guard’s Thwarting of Administrative Remedies, Aug. 1, 2025. Retaliation for Filing Grievances, Administrative Exhaustion (PLRA), Grievances.
- Second Circuit Revives Connecticut Prisoner’s Challenge To Conditions In Virginia Lockup Where He Was Transferred, May 1, 2025. Transfers, Retaliatory Transfers, Totality of Conditions, Administrative Law/Remedies.
- $500 Jury Verdict for Pennsylvania Prisoner After Federal Court Clarifies DOC Grievance Procedures, Nov. 15, 2024. Settlements, Grievances.
- Seventh Circuit Avoids Deciding Whether Wisconsin Statute of Limitations Tolls from Prisoner’s Incident or Grievances, Oct. 15, 2024. Grievances, Tolling of Statutes of Limitations and Laches.

