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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
- North Carolina Reimburses Prisoner $2,500 for Law Books Destroyed by Guards, by Anthony Accurso
- No State Oversight of Overcrowded, Understaffed, and Non-Compliant Idaho Jails
- 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
- Tucson Program Slashes Pretrial Misdemeanor Incarceration
- $1 Million Partial Settlement for Washington Jail Detainee’s Leg Amputation
- 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
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- GOP Washington Lawmaker Trolls Felon Enfranchisement Proponents
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- 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
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More from these topics:
- BOP Ordered to Restart Gender Affirming Care for Trans Prisoners, July 1, 2026. Medical, Conditions of Confinement, Administrative Exhaustion (PLRA), Transgender.
- Seventh Circuit Reinstates Illinois Prisoner’s Lawsuit Against Prison Dental Staff, June 1, 2026. Dental Care, Administrative Exhaustion (PLRA), Summary Judgment, Class Certification, Deliberate Indifference.
- Federal Court Partially Enjoins Enforcement of Georgia’s S.B. 185 Prohibiting Gender-Affirming Health Care in DOC, June 1, 2026. Medication, Failure to Treat, Injunctions, Transgender Medical Procedures, Cruel and Unusual Punishment.
- Fourth Circuit Revives Detainee’s Suit Alleging Monell and 14th Amendment Deliberate Indifference Claims, June 1, 2026. Medication, Private Contractors, Failure to Treat, Monell Liability, Deliberate Indifference.
- 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.
- 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.

