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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 …
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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
- 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:
- California Appeals Court Sustains Amendments to CDCR that Narrow Youth Parole Eligibility Rules, July 1, 2026
- Eighth Circuit Revives § 1983 Complaint Alleging Jail Detainees’ Death from Stroke was Due to Deliberate Indifference and Failure to Train, July 1, 2026
- California Court of Appeal Announces Defendants Who Exercise Right to Jury Trial on Aggravating Circumstances Are Entitled to Closing Argument by Counsel on Those Factors, July 1, 2026
- SCOTUS Holds Federal Habeas Court May Not Consider Post-Trial DNA Evidence That Was Never Presented to Jury When Assessing Whether False Informant Testimony Influenced Verdict, July 1, 2026
- Supreme Court of Appeals of West Virginia Announces Six-Factor Test for Evaluating Presentence Motions to Withdraw Guilty Pleas Under Rule 32(e), Holds Binding Plea Agreement Does Not Extinguish Defendant’s Ability to Seek Withdrawal, July 1, 2026
- New Jersey Lawmakers Pass “Female Incarcerated Person’s Rights Protection Act”, July 1, 2026
- Louisiana’s Atavistic Approach to Criminal Sentencing and Parole Demonstrates Politicians’ Failure to Learn from Past Mistakes, July 1, 2026
- California Supreme Court Announces Amended § 1170(b) Applies Retroactively to Plea-Bargained Upper Term Sentences, July 1, 2026
- Michigan Supreme Court Announces Betts Decision Invalidating 2011 SORA as Ex Post Facto Punishment Applies Retroactively to Defendants on Collateral Review, July 1, 2026
- South Carolina Supreme Court Announces Formal Adoption of Fourth Circuit’s Three-Step Cheek Framework for Evaluating Improper Third-Party Contacts With Jurors Under Remmer, Reverses Murdaugh Murder Convictions, and Overrules Ethier Regarding Juror Testim, July 1, 2026
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.
- New Jersey Lawmakers Pass “Female Incarcerated Person’s Rights Protection Act”, July 1, 2026. Staff-Prisoner Assault, Guard Misconduct, Prison Rape Elimination Act, Staff Training, Mothers in Prison.
- 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 Jury Awards $2,500 to Male Wisconsin Prisoner Sexually Assaulted by Female Guard, June 1, 2026. Staff-Prisoner Assault, Guard Misconduct, Evidence, Prison Rape Elimination Act, Cruel and Unusual Punishment.
- 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.

