Porter v. Nussle
Annotate this Case
534 U.S. 516 (2002)
OCTOBER TERM, 2001
PORTER ET AL. v. NUSSLE
CERTIORARI TO THE UNITED STATES COURT OF APPEALS FOR THE SECOND CIRCUIT
No. 00-853. Argued January 14, 2002-Decided February 26, 2002
Without filing a grievance under applicable Connecticut Department of Correction procedures, plaintiff-respondent Nussle, a state prison inmate, commenced a federal-court action under 42 U. S. C. § 1983, charging that corrections officers, including defendant-petitioner Porter, had subjected him to a sustained pattern of harassment and intimidation and had singled him out for a severe beating in violation of the Eighth Amendment's ban on "cruel and unusual punishments." The District Court dismissed Nussle's suit, relying on a provision of the Prison Litigation Reform Act of 1995 (PLRA), 42 U. S. C. § 1997e(a), that directs:
"No action shall be brought with respect to prison conditions under section 1983 ... , or any other Federal law, by a prisoner ... until such administrative remedies as are available are exhausted." The Second Circuit reversed, holding that exhaustion of administrative remedies is not required for a claim of the kind Nussle asserted. The appeals court concluded that § 1997e(a)'s "prison conditions" phrase covers only conditions affecting prisoners generally, not single incidents that immediately affect only particular prisoners, such as corrections officers' use of excessive force. In support of its position, the court cited legislative history suggesting that the PLRA curtails frivolous suits, not actions seeking relief from corrections officer brutality; the court also referred to prePLRA decisions in which this Court distinguished, for proof of injury and mens rea purposes, between excessive force claims and conditions of confinement claims.
Held: The PLRA's exhaustion requirement applies to all inmate suits about prison life, whether they involve general circumstances or particular episodes, and whether they allege excessive force or some other wrong. Cf. Wilson v. Seiter, 501 U. S. 294, 299, n. 1. Pp. 523-532.
(a) The current exhaustion provision in § 1997e(a) differs markedly from its predecessor. Once within the district court's discretion, exhaustion in § 1997e(a) cases is now mandatory. See Booth v. Churner, 532 U. S. 731, 739. And unlike the previous provision, which encompassed only § 1983 suits, exhaustion is now required for all "action[s] ... brought with respect to prison conditions." Section 1997e(a), designed to reduce the quantity and improve the quality of prisoner suits, affords corrections officials an opportunity to address complaints internally
before allowing the initiation of a federal case. In some instances, corrective action taken in response to an inmate's grievance might improve prison administration and satisfy the inmate, thereby obviating the need for litigation. Id., at 737. In other instances, the internal review might filter out some frivolous claims. Ibid. And for cases ultimately brought to court, an administrative record clarifying the controversy's contours could facilitate adjudication. See, e. g., ibid. Pp. 523-525.
(b) Determination of the meaning of § 1997e(a)'s "prison conditions" phrase is guided by the PLRA's text and context, and by this Court's prior decisions relating to "[sJuits by prisoners," as § 1997e is titled. The pathmarking opinion is McCarthy v. Bronson, 500 U. S. 136, in which the Court construed the Federal Magistrates Act's authorization to district judges to refer "prisoner petitions challenging conditions of confinement" to magistrate judges. This Court concluded in McCarthy that, read in its proper context, the phrase "challenging conditions of confinement" authorizes the nonconsensual reference of all prisoner petitions to a magistrate, id., at 139. The McCarthy Court emphasized that Preiser v. Rodriguez, 411 U. S. 475, had unambiguously placed cases involving single episodes of unconstitutional conduct within the broad category of prisoner petitions challenging conditions of confinement, 500 U. S., at 141; found it telling that Congress, in composing the Magistrates Act, chose language that so clearly paralleled the Preiser opinion, 500 U. S., at 142; and considered it significant that the latter Act's purpose-to lighten overworked district judges' caseload-would be thwarted by allowing satellite litigation over the precise contours of an exception for single episode cases, id., at 143. The general presumption that Congress expects its statutes to be read in conformity with this Court's precedents, United States v. Wells, 519 U. S. 482, 495, and the PLRA's dominant concern to promote administrative redress, filter out groundless claims, and foster better prepared litigation of claims aired in court, see Booth v. Churner, 532 U. S., at 737, persuade the Court that § 1997e(a)'s key words "prison conditions" are properly read through the lens of McCarthy and Preiser. Those decisions tug strongly away from classifying suits about prison guards' use of excessive force, one or many times, as anything other than actions "with respect to prison conditions." Nussle misplaces principal reliance on Hudson v. McMillian, 503 U. S. 1, 8-9, and Farmer v. Brennan, 511 U. S. 825, 835-836. Although those cases did distinguish excessive force claims from conditions of confinement claims, they did so in the context of proof requirements: what injury must a plaintiff allege and show; what mental state must a plaintiff plead and prove. Proof requirements, once a case is in court, however, do not touch or concern