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Appeals Court Rules Michigan’s Tolling Provision Is Not Inconsistent with the PLRA
by Douglas Ankney
The U.S. Court of Appeals for the Sixth Circuit ruled on January 29, 2025 that Michigan’s tolling provision codified in Mich. Comp. Laws section 600.5856 is not inconsistent with the Prison Litigation Reform Act of 1995 (PLRA).
On March 2, 2018, prisoner Lamont Bernard …
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More from this issue:
- America’s Deadliest Jails: Tarrant County Edition, by Anthony Accurso
- Washington Prisoners Gain Access to Crisis Hotline
- From the Editor, by Paul Wright
- HRDC’s Washington Jail Debit-Release Card Suit Survives Summary Judgment, by Chuck Sharman
- $11 Million Paid to Estate of Mentally Ill Illinois Jail Detainee Who Lost 60 Pounds During 85-Day Incarceration, by Chuck Sharman
- Missouri Blocks Spiritual Advisors from Prison Pastor’s Execution, by Jo Ellen Nott
- Dying Mississippi Prisoner Wins Preservation Testimony in Suit Blaming Terminal Cancer on Exposure to Janitorial Chemicals, by Chuck Sharman
- Ninth Circuit Finds No Bivens Extension Needed for Federal Prisoner Prescribed Water and Exercise for Thyroid Storms, by Chuck Sharman
- Trans Kentucky Prisoner Loses Bid to Block State’s New Ban on Hormone Replacement Therapy, by Chuck Sharman
- Enormous $14 Million Settlement Reached by Los Angeles County with Former Prisoner Exonerated After 20 Years, by Chuck Sharman
- San Diego County Files Unusual Suit Against NaphCare Over Jail Detainee’s Murder, by Chuck Sharman
- For Delay in Summoning Medical Care for Detainees, Alabama Jailers Granted Immunity But California Trooper Headed to Trial, by Chuck Sharman
- Seventh Circuit Rules Against Prisoner’s Deliberate Indifference Claim Over Wexford Health’s Poor Psychiatric Care, by Michael Thompson
- Sixth Circuit Clarifies What Constitutes PLRA “Strike” and Reinstates Michigan Prisoner’s Lawsuit, by Matthew Clarke
- $2.4 Million Paid to Indiana Prisoners Sickened With Legionnaire’s Disease by Contaminated Water, by Chuck Sharman
- CoreCivic Pays $82,500 for First COVID-19 Death at San Diego ICE Lockup, by Chuck Sharman
- Body-Worn Camera Program for Guards Expands to all Maryland Prisons, by Chuck Sharman
- Wisconsin DOC Ordered to Provide Programming for Pregnant Prisoners—34 Years After Law Was Passed, by Chuck Sharman
- Securus Loses Bid to Dismiss HRDC Price-Fixing Suit, by Chuck Sharman
- $150,000 Paid by Jacksonville for Mother of Five’s Jail Suicide, by Chuck Sharman
- Federal Injunction Bars ICE from Crowding Detainees in Unsanitary “Hold” Rooms in New York City Office, by Chuck Sharman
- While Mentally Ill Rikers Island Detainee Lay Dying, Staff Sprayed Air Freshener, Fudged Cell Checks, by Chuck Sharman
- SCOTUS Overturns Oklahoma Prisoner’s Death Sentence After More than 25 Years on Death Row, by Douglas Ankney
- $1.8 Million Settlement Reached Following CDCR Data Breach, by Chuck Sharman
- North Carolina Prison Officials Run Out the Clock On Trans Prisoner’s Vulvoplasty, by Chuck Sharman
- Seventh Circuit Dismisses Jail Detainee Suicide Case for Lack of Showing Deliberate Indifference, by Anthony Accurso
- Jailhouse Lawyer Gets 16-1/2-Year Sentence for Defrauding Prisoner “Clients”, by Chuck Sharman
- Fourth Circuit Rules in Favor of Prisoner’s Eligibility for Time Credits, by Douglas Ankney
- Federal Government, CoreCivic Slow-Walk Class-Action Challenges to Forced Labor of ICE Detainees, by Chuck Sharman
- Oklahoma County Jailers Lose Bids to Derail Three Suits Over Detainee Murders, by Chuck Sharman
- Ohio Appoints Special Prosecutor to Investigate Double Amputee’s Restraint and Death
- South Dakota Approves $650 Million New Prison Construction
- Fifth Circuit Remands Louisiana Detainee’s Medical Grievance Case, by Michael Thompson
- Eighth Circuit Orders Preliminary Injunction Requiring Minnesota to Reinstate Program Teaching Biblical “Authentic Manhood”, by Matthew Clarke
- Appeals Court Rules Michigan’s Tolling Provision Is Not Inconsistent with the PLRA, by Douglas Ankney
- California’s Attorney General Is Suing Los Angeles County Jails Over “Inhumane Conditions”, by Michael Thompson
- FCC Issues Proposed Rule Permitting Cellphone Jammers in Prisons and Jails, by Chuck Sharman
- Preliminary Injunction Halts Solitary Confinement of Mentally Ill Prisoners at New York Lockup Where Wildcat Guard Strike Began, by Chuck Sharman
- Florida Sheriff Fires Five Guards for Two Cases of Detainee Abuse
- $5.5 Million Paid for Two Withdrawal Deaths at Washington Jail, by Chuck Sharman
- $950,000 Awarded to Trans Maryland Prisoner Dropped on Her Face by Guards, by Douglas Ankney
- Seventh Circuit Affirms Liberty Interest in Harsh Solitary Confinement Case, by Michael Thompson
- Eleventh Circuit Overturns 1990 Alabama Death Sentence Over Racially Biased Jury Selection; ACLU Report Shows It Is Still Happening, by Matthew Clarke
- Eleventh Circuit Declines to Extend to Summary Judgment Proceedings a Rule Requiring District Courts to Notify Pro Se Litigants, by Douglas Ankney
- BOP Cancels Union Rights for Prison Guards
- $4 Million Verdict Returned in Colorado Jail Suicide Case, by Chuck Sharman
- $100,000 Settlement Reached Between Imprisoned BOP Guard and Prisoners He Raped, by Chuck Sharman
- Fifth Circuit Dismisses Sex Abuse Claims Filed by Three Texas Prisoners Against Guard, by Chuck Sharman
- Nearly $528,000 Paid by Kansas Jail to Detainees Raped by Guards, by Chuck Sharman
- New York Jury Convicts Former Guard for Robert Brooks’ Taped Killing
- Two Re-Entry Non-Profit Leaders in Tennessee and Massachusetts Accused of Criminal Charges
- The Last Escaped Detainee from the New Orleans Jail Was Arrested in an Atlanta Crawlspace
- California Approves Higher Wage for Prisoner Firefighters (But Still Underpays)
- Former Prisoners’ Challenge to Virginia Constitution’s Felony Disenfranchisement Clause Allowed to Proceed, by Douglas Ankney
- $3.6 Million Paid by Minnesota County After Hemophiliac Jail Detainee Died from Brain Bleed, by Chuck Sharman
- Appeals Court Allows Illinois Prisoner’s Suit for Failure to Exhaust Administrative Remedies, by Douglas Ankney
- FCC Votes For Dramatic Hike to Prison Phone Call Rates, by Chuck Sharman
- News in Brief
More from Douglas Ankney:
- Second Circuit Vacates Above-Guidelines Firearm-Trafficking Sentence Based on Failure to Assist Law Enforcement and Unexplained Reliance on Factors Already Included in Guidelines Range, Sept. 1, 2026
- Ninth Circuit Reverses Convictions, Holding Requirement That Defendant Testify Before Displaying Hand Tattoos Violates Fifth Amendment, Sept. 1, 2026
- Ohio Supreme Court Announces Postconviction DNA-Testing Orders Need Only Identify Statutory Reason to Satisfy R.C. 2953.73(D) “Reasons” Requirement, Sept. 1, 2026
- Idaho Legislature Moves to Hide Execution Protocol from Judicial Scrutiny, Sept. 1, 2026
- New Jersey Court Rules That Denial of Transgender Prisoner’s Transfer Request Violates Neither Discrimination Law nor Equal Protection Clause, Sept. 1, 2026
- Federal Court Upholds Consultants’ Finding that Oklahoma Is Not Honoring Its Consent Decree to Provide Mental Health Treatment, Sept. 1, 2026
- BOP Denies Providing Substandard Dialysis Treatment Despite Prisoners’ Deaths, Court Filings, Understaffing and Lack of Oversight, Sept. 1, 2026
- New Jersey Supreme Court Orders Plenary Hearing Before Special Adjudicator on Reliability of Fingerprint Evidence, Holding Century of Judicial Acceptance Did Not Satisfy Trial Court’s Gatekeeping Obligation Under N.J.R.E. 702, Aug. 1, 2026
- En Banc Eleventh Circuit Announces All Parents, Including Those Convicted of Child-Sex Offenses, Enjoy Fundamental Right to Live With Their Children, Holding Alabama Residency Prohibition Subject to Strict Scrutiny, Aug. 1, 2026
- Seventh Circuit Announces Courts May Examine Individual Officer’s Subjective Purpose When Assessing Whether Warrantless Administrative Inspection Was Pretextual, Holding Suppression Required Where Trooper’s Sole Motive for Stop Was Criminal Investigati, Aug. 1, 2026
More from these topics:
- Florida DOC Rebuked for Seizing Prisoner’s Excessive Force Settlement to Cover Incarceration Liens, Sept. 1, 2026. Summary Judgment, Settlements, Seizure of Prisoner Funds, Trust Accounts, 42 U.S. Code § 1983, civil action for deprivation of rights.
- $500,000 for Mentally Ill Detainee Beaten by Guard at Ohio Jail, Sept. 1, 2026. Guard Brutality/Beatings, Summary Judgment, Settlements, 42 U.S. Code § 1983, civil action for deprivation of rights, Monell Liability.
- Sixth Circuit Holds Kentucky Deficient-Counsel Belated-Appeal Procedure Tolls Federal Habeas One-Year Limitations Period, Sept. 1, 2026. Limitations, Habeas Corpus, AEDPA, Failure to Preserve Challenge, Tolling of Statutes of Limitations and Laches.
- 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.
- Detroit Pays $5.8 Million to Former State Prisoner Exonerated of Murder After 15 Years, Aug. 1, 2026. Wrongful Conviction, Qualified Immunity, 42 U.S. Code § 1983, civil action for deprivation of rights, Eyewitness Identification, Evidence - Failure to Disclose.
- Oregon Agrees to $2.3 Million Settlement After Guards Toss Mentally Ill Prisoner in Solitary, Taunt Him Until He Kills Himself, Aug. 1, 2026. Control Units/SHU/Solitary Confinement, Failure to Treat (Mental Illness), Suicides, 42 U.S. Code § 1983, civil action for deprivation of rights, Deliberate Indifference.
- $1.2 Million for Elderly Detainee Shoved Out the Door of Sacramento Jail by Guard, Aug. 1, 2026. Guard Brutality/Beatings, Americans with Disabilities Act, Rehabilitation Act, Failure to Treat (Mental Illness), 42 U.S. Code § 1983, civil action for deprivation of rights.
- $30,000 Settlement Reached in Virginia Jail Death That Put Richmond Lockup Under State Oversight, Aug. 1, 2026. Jail Misconduct, Failure to Protect (General), Staffing, 42 U.S. Code § 1983, civil action for deprivation of rights, Monell Liability.
- Seventh Circuit Grants Qualified Immunity to Detectives Who Revealed Prisoner Was Informant, Denies Him Anonymity, Aug. 1, 2026. Failure to Protect (General), Physical Injury Rule, Qualified Immunity, Informants (Failure to Protect), 42 U.S. Code § 1983, civil action for deprivation of rights.
- $25,000 Paid to Former New York Jail Detainee Subjected to Delayed Healthcare and Denied Mental Healthcare— Despite Seven Suicide Attempts, July 1, 2026. Failure to Treat, Conditions of Confinement, Mental Health, 42 U.S. Code § 1983, civil action for deprivation of rights, Deliberate Indifference.

