×
You've used up your 3 free articles for this month. Subscribe today.
Fourth Circuit Excuses Maryland Prisoner From Exhaustion Requirement in PREA Claim
by Douglas Ankney
In what was otherwise a disappointing ruling for a Maryland prisoner, the United States Court of Appeals for the Fourth Circuit held on June 14, 2024, that a prisoner need not exhaust administrative remedies before filing suit accusing officials of sexual misconduct that is not …
Full article and associated cases available to subscribers.
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
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
- GTL, Co-Defendant Agree to $21.3 Million Settlement 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
- California Stops Raiding Released Prisoners’ Gate Money
- $4 Million Settlement Approved in HRDC’s Oregon Debit-Release Card Suit
- Nurse Charged, $2.6 Million Settlement Reached in Minnesota Jail Death
- 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
- Georgia Fights Liability for Strip-Searching Prison Visitor, Nevada Pays $126,500
- Half of Hawai’i Prisoners Released With No ID
- Peters Fights Dismissal from BOP, Guards Lose Bonus Pay
- Southern Health Partners Settles Suit Over Kentucky Jail Meth Death
- Federal Watchdog Calls Out BOP for Spiking Suicide Risk at Pennsylvania Lockup, by Matthew Clarke
- Wisconsin DOC Agrees to Improve Services for Hearing-Impaired Prisoners
- $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 Douglas Ankney:
- Pregnant Women Detained in Jail: The Hideous Story of In-Custody Births, May 1, 2026
- Idaho DOC Director Denies Verified Report of Rampant Sexual Abuse of Women Prisoners by Staff, May 1, 2026
- Fourth Circuit Announces Defendant Has Standing to Appeal Based Solely on Rogers–Singletary Claim of a “Material Discrepancy Between” Written and Orally Articulated Judgment at Sentencing, May 1, 2026
- Illinois Jail Reprimanded for Denying Detainees Mail Based on Media Content, P.O. Box Return Address, Settles Detainees’ Suit with $111,825 Payment of Legal Fees, May 1, 2026
- Sixth Circuit Announces Federal Coercion and Enticement Statute Requires Knowledge of Victim’s Minor Status, Deepening Circuit Split, May 1, 2026
- Oklahoma Supreme Court: Jail Trust Cannot Withhold Requested Records under Law Enforcement Exemption of ORA, May 1, 2026
- Delaware Supreme Court Announces Adoption of ABA Standard 3-6.5(b) Governing Prosecutors’ Opening Statements, Reverses Murder Convictions Based on Prosecutor’s References to Co-Defendant’s Guilty Plea, May 1, 2026
- Tenth Circuit Holds Prior California Child Pornography Conviction Does Not Trigger Federal Mandatory Minimum Because State Statute Encompasses Conduct Beyond Federal Definition Under Categorical Approach, April 1, 2026
- Kentucky Supreme Court Clarifies Parole Board May Delegate Final Revocation Hearings to Administrative Law Judges but Holds Due Process Requires Parolees Be Permitted to File Exceptions to ALJ Findings Before Board Renders a Final Revocation Decision, April 1, 2026
- New York Court of Appeals Holds Generic Physical Description Insufficient to Justify Pursuit in Mistaken Identity Case, and Suspect’s Flight Cannot Support Reasonable Suspicion Absent Evidence He Knew He Was Fleeing Law Enforcement, April 1, 2026
More from these topics:
- Idaho DOC Director Denies Verified Report of Rampant Sexual Abuse of Women Prisoners by Staff, May 1, 2026. Staff-Prisoner Assault, Guard Misconduct, DOC/BOP misconduct, Retaliatory Segregation, Prison Rape Elimination Act.
- 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).
- Idaho Struggles to Respond to Devasting Report of Widespread Prisoner Sex Abuse, April 1, 2026. Staff-Prisoner Assault, Guard Misconduct, Prison Rape Elimination Act, State Legislation, Public Records Act.
- Ohio Supreme Court Awards Prisoner $1,000 for Denied Records Request, April 1, 2026. Administrative Exhaustion (PLRA), Damages, Public Records, Public Records Act.
- Leaked Video Footage Shows California Prison Guards Engaged in Retaliatory Assault, March 1, 2026. Guard Misconduct, Retaliation for Filing Grievances, Pepper Spray/Tear Gas, Prison Rape Elimination Act.
- Eighth Circuit Revives Case Against Guards Who Failed to Intervene As Chaplain Sexually Assaulted Arkansas Prisoner, March 1, 2026. Staff-Prisoner Assault, Failure to Protect (General), Prison Rape Elimination Act, Qualified Immunity, Failure to Train/Supervise.
- 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.
- 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.
- The DOJ Orders Prison Inspectors to Drop LGBTQ+ Protections, Jan. 1, 2026. Sexual Assault, Corrections Audits, Prison Rape Elimination Act, Discrimination (Transgender), Failure to Protect (Transgender).
- 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.

