Woodford v. Ngo

The District Court granted the prison officials' motion to dismiss on the ground that respondent had not fully exhausted his administrative remedies under the PLRA.

The Ninth Circuit Court of Appeals reversed, holding that respondent had exhausted those remedies because none remained available to him.

Justice Alito, for the majority, ruled in favor of the prison officials, writing that "proper exhaustion demands compliance with an agency's deadlines and other critical procedural rules because no adjudicative system can function effectively without imposing some orderly structure on the course of its proceedings."

The point of the PLRA, he continues, is to avoid "unwarranted federal-court interference with the administration of prisons," and to allow Ngo's interpretation would frustrate the goal of the legislation.

In that dissent, joined by Justices Souter and Ginsburg, Stevens writes that "The plain text of the PLRA simply requires that such administrative remedies as are available be exhausted before the prisoner can take the serious step of filing a federal lawsuit against the officials who hold him in custody."