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D.C. Circuit Reverses Dismissal of Federal Prisoner’s Complaint Due to PLRA Three-Strikes Rule
Loaded on April 1, 2025
published in Prison Legal News
April, 2025, page 60
Filed under:
Medication,
Administrative Exhaustion (PLRA),
Pending Appeals.
Location:
District of Columbia.
In a ruling on October 18, 2024, the United States Court of Appeals for the District of Columbia Circuit revived a case filed by federal prisoner Michael S. Owlfeather-Gorbey. A “prolific litigator” housed at the U.S. Penitentiary in Thompson, Illinois, he sued federal Bureau of Prisons (BOP) officials in …
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More from this issue:
- Deaths, Deplorable Conditions, Staff Misconduct Plague Memphis Jail
- From the Editor, by Paul Wright
- New Jersey Guard Sacked for Mocking George Floyd Killing Loses Appeal
- New York Suspends Solitary Ban to Woo Back Striking Prison Guards
- Porn Produced by Georgia Prisoners
- $7.15 Million for Oklahoma Prisoner Exonerated After Nearly 50 Years, by Anthony Accurso
- No State Oversight of Overcrowded, Understaffed, and Non-Compliant Idaho Jails
- North Carolina Reimburses Prisoner $2,500 for Law Books Destroyed by Guards, by Anthony Accurso
- No Sunshine on In-Custody Deaths in Sunshine State
- Little-Known Law Allows Some Texas Prisoners to Vote
- $1.35 Million in Settlements for One-Legged San Francisco Detainee Forced to Hop—Twice
- Ohio Pauses Executions, Louisiana and Arizona Race Ahead
- Self-Harming Wisconsin Prisoner Settles Failure-to-Protect Suit for $7,000, by Sam Rutherford
- Biden Clemency Recipients Included Virginians Sentenced for “Acquitted Conduct”
- 14 Overdoses in Two Weeks Leave One Dead at Phoenix Jail
- “Swing or Kick Rocks”: BOP Guard Alleges Conspiracy to Brutalize Prisoners at Kentucky Lockup
- $1 Million Partial Settlement for Washington Jail Detainee’s Leg Amputation
- Tucson Program Slashes Pretrial Misdemeanor Incarceration
- Tenth Circuit Stretches PLRA to Deny Claim of Colorado Prisoner Shot by Guard While Shackled, by Douglas Ankney
- $42 Million Jury Award for Detainees Tortured by U.S. Military at Abu Ghraib Prison
- Pardoned Insurrectionists Brought to D.C. Jail Demanded Others’ Immediate Release
- Houston Jail Cited for State-Law Violations Twice in a Month
- A Song for Condemned Alabama Prisoner
- Three Former Virginia Jailers Charged After Detainee Dies in “WRAP” Restraint
- Ninth Circuit: No Exception to Due Diligence in Discovery Even for “Conclusive Evidence”, by Anthony Accurso
- Sixth Circuit: Dismissals of Mixed-Claim Complaints Not Strikes Under PLRA
- Former Indiana Jailer Walks from Charges Over “Night of Terror”
- National Class Certified in Washington Jail Debit-Release Card Suit
- CoreCivic Will Cage Migrant Families in Texas Lockup
- Three More Prisoners Die, Three More Staffers Fired at Wisconsin Prison
- Jailing the Homeless: New Data Shed Light on Unhoused People in Local Jails, by Leah Wang
- GTL, Co-Defendant Agree to $21.3 Million Settlement with HRDC in Price-Fixing Lawsuit
- No Opened Envelopes: Hawai’i Prisons Get New Mail Scanning Technology
- GEO Group Gets $1 Billion ICE Contract at New Jersey Lockup
- DOJ Finds “Horrific” Unconstitutional Conditions at Atlanta Jail
- Alabama Governor Commutes Death Sentence
- Nurse Charged, $2.6 Million Settlement Reached in Minnesota Jail Death
- $4 Million Settlement Approved in HRDC’s Oregon Debit-Release Card Suit
- California Stops Raiding Released Prisoners’ Gate Money
- Tenth Alabama Jail Employee Pleads Guilty in Detainee’s Freezing Death
- Muslim Prisoners Face Price-Gouging
- $250,000 Settlement But No Charges After Alabama Guards Beat Prisoner To Death, by Anthony Accurso
- GOP Washington Lawmaker Trolls Felon Enfranchisement Proponents
- Ninth Circuit: Posting Jail Mugshots on Arizona County’s Website Violates Substantive Due Process
- Half of Hawai’i Prisoners Released With No ID
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- $2.5 Million Settlement After South Carolina Jail Detainee Lost 2 Lbs.Per Day and Died, by Anthony Accurso
- More New York Guards Suspended After Another Prisoner’s Fatal Beating
- Fourth Circuit Excuses Maryland Prisoner From Exhaustion Requirement in PREA Claim, by Douglas Ankney
- Eighth Circuit: Arkansas Prisoner Who Had Consensual Sex With Guard Cannot Sustain Eighth Amendment Claim, by Matthew Clarke
- Illinois Pretrial Incarceration Becomes Less Random A Year After Elimination of Cash Bail, by David Reutter
- D.C. Circuit Reverses Dismissal of Federal Prisoner’s Complaint Due to PLRA Three-Strikes Rule
- TDCJ to Run Out of Beds in 2025, by Matthew Clarke
- News in Brief
- Shrewd Federal Prisoner Salvages $5,000 from Suit Against Arkansas Jail Where He Was Held Pre-Trial, by Anthony Accurso
More from these topics:
- Ohio Supreme Court Awards Prisoner $1,000 for Denied Records Request, April 1, 2026. Administrative Exhaustion (PLRA), Damages, Public Records, Public Records Act.
- Wisconsin’s Incarcerated Population Has More Access to Opioid Treatment, But Still Missing in Eight County Jails, April 1, 2026. Medication, Drug/Alcohol Withdrawal, Drug Treatment/Rehab, Health care.
- 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.
- Medical Audit at New Mexico Jail Once Again Finds Poor Level of Healthcare, March 1, 2026. Medication, Systemic Medical Neglect, Drug/Alcohol Withdrawal, Contagious Disease -- Misc., Staffing.
- Los Angeles County Restricts Opioid Treatment, Feb. 1, 2026. Medication, Systemic Medical Neglect, Failure to Treat, Drug Overdose, Drug Treatment/Rehab.
- $2.75 Million Paid by Washington County and NaphCare for Death of “Floridly Psychotic” Detainee Left Untreated in Jail for Months, Jan. 1, 2026. Naphcare, Medication, Systemic Medical Neglect, Failure to Treat (Mental Illness), Deliberate Indifference.
- 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.
- Sixth Circuit Affirms Denial of Qualified Immunity to Jail Nurses in Suit Arising from Prisoner’s Death, Dec. 1, 2025. Medication, Failure to Treat, Qualified Immunity, Medical Neglect/Malpractice, Deliberate Indifference.
- 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.

