woodford et al ngo argued march decided june prison litigation reform act plra requires prisoner exhaust available administrative remedies challenging prison conditions federal respondent filed grievance california prison officials prison conditions rejected untimely state law subsequently sued petitioner officials federal district granted petitioners motion dismiss ground respondent fully exhausted administrative remedies reversing ninth circuit held respondent exhausted remedies none remained available held plra exhaustion requirement requires proper exhaustion administrative remedies pp petitioners claim prisoner must complete administrative review process accordance applicable procedural rules including deadlines precondition bringing suit federal respondent contends allows suit administrative remedies longer available regardless reason determine correct interpretation looks guidance administrative habeas corpus law exhaustion important doctrine administrative law requires proper exhaustion administrative remedies means using steps agency holds properly pozo mccaughtry habeas law substantively similar rules though terminology different pp given background persuaded plra requires proper exhaustion pp referring administrative remedies available text strongly suggests exhausted means means administrative law construing require proper exhaustion also serves plra goals gives prisoners effective incentive make full use prison grievance process thus providing prisons fair opportunity correct errors reduces quantity prisoner suits improves quality suits filed proper exhaustion often results creation administrative record helpful contrast respondent interpretation make plra exhaustion scheme totally ineffective since exhaustion benefits realized prison grievance system given fair opportunity consider grievance happen unless grievant complies system critical procedural rules respondent arguments interpretation filter frivolous claims unpersuasive pp interpreted respondent plra exhaustion requirement unprecedented statute case purports require exhaustion time allowing party bypass deliberately administrative process flouting agency procedural rules none models apt first suggests plra requirement patterned habeas law existed fay noia federal habeas claim procedurally defaulted prisoner deliberately bypassed state remedies fanciful however plra enacted contemporaneously antiterrorism effective death penalty act gave federal habeas review structure markedly different existed furthermore respondent interpretation duplicate scheme permit prisoner bypass deliberately administrative review risk sanction respondent next suggests plra exhaustion requirement patterned age discrimination employment act title vii civil rights act neither provision sense exhaustion provision pp respondent remaining arguments regarding interpretation also unconvincing pp reversed remanded alito delivered opinion roberts scalia kennedy thomas joined breyer filed opinion concurring judgment stevens filed dissenting opinion souter ginsburg joined jeanne woodford et petitioners viet mike ngo writ certiorari appeals ninth circuit june justice alito delivered opinion case presents question whether prisoner satisfy prison litigation reform act exhaustion requirement filing untimely otherwise procedurally defective administrative grievance appeal hold proper exhaustion administrative remedies necessary congress enacted prison litigation reform act plra stat amended et wake sharp rise prisoner litigation federal courts see alexander hawk citing statistics plra contains variety provisions designed bring litigation control see requiring district courts weed prisoner claims clearly lack merit prohibiting claims emotional injury without prior showing physical injury restricting attorney fees centerpiece plra effort reduce quantity prisoner suits invigorated exhaustion provision porter nussle prisoners asserting constitutional claims obligation exhaust administrative remedies see wilwording swenson per curiam civil rights institutionalized persons act stat congress enacted weak exhaustion provision authorized district courts stay actions rev stat limited time prisoner exhausted plain speedy effective administrative remedies available exhaustion prescription large part discretionary ordered state prison grievance system met specified federal standards even particular case believed requirement interests justice nussle supra quoting addition provision require exhaustion prisoner sought money damages relief available relevant administrative scheme see mccarthy madigan plra strengthened exhaustion provision several ways exhaustion longer left discretion district mandatory see booth churner prisoners must exhaust available remedies meet federal standards indeed held booth prisoner must exhaust administrative remedies even relief sought monetary damages granted administrative process finally exhaustion available administrative remedies required suit challenging prison conditions suits nussle supra california grievance system prisoners seek challenge conditions confinement initiate process inmate must fill simple form dept corrections appeal form cdc hereinafter form made readily available inmates cal code tit inmate must fill two parts form part labeled describe problem part labeled action requested explained form prisoner must first informally seek relief discussion appropriate staff member app staff member fills part form heading staff response returns form inmate prisoner dissatisfied result informal review informal review waived state inmate may pursue review process see although california labels formal review apparently distinguish process prior step process relatively simple first level prisoner must fill part form dissatisfied explain inmate must submit form together documents appeals coordinator within working days three weeks action taken level may bypassed appeals coordinator certain circumstances within working days inmate submits appeal reviewer must inform inmate outcome completing part form returning form inmate prisoner receives adverse determination first level level bypassed inmate may proceed second level review conducted warden inmate filling part form submitting form within working days prior decision within working days thereafter reviewer provides decision letter attached form prisoner claim denied prisoner otherwise dissatisfied result prisoner must explain basis dissatisfaction part form mail form director california department corrections rehabilitation within working days inmate appeal may rejected ime limits submitting appeal exceeded appellant opportunity file within prescribed time constraints respondent prisoner convicted murder serving life sentence california prison system october respondent placed administrative segregation allegedly engaging inappropriate activity prison chapel two months later respondent returned general population respondent claims prohibited participating special programs including variety religious activities approximately six months restriction imposed respondent filed grievance prison officials challenging action grievance rejected untimely filed within working days action challenged see respondent appealed decision internally without success subsequently sued petitioners california correctional officials federal district district granted petitioners motion dismiss respondent fully exhausted administrative remedies required see app pet cert appeals ninth circuit reversed held respondent exhausted administrative remedies simply remedies remained available ninth circuit decision consistent decision divided panel sixth circuit thomas woolum conflicts decisions four courts appeals see pozo mccaughtry exhaust remedies prisoner must file complaints appeals place time prison administrative rules require cert denied ross county bernalillo spruill gillis johnson meadows granted certiorari address conflict reverse ii plra provides follows action shall brought respect prison conditions section title federal law prisoner confined jail prison correctional facility administrative remedies available exhausted ed emphasis added dispute language requires prisoner exhaust administrative remedies parties differ sharply understanding meaning requirement petitioners argue provision requires proper exhaustion means according petitioners prisoner must complete administrative review process accordance applicable procedural rules including deadlines precondition bringing suit federal respondent hand argues provision demands terms exhaustion simpliciter brief respondent view simply means prisoner may bring suit federal administrative remedies longer available interpretation reason administrative remedies longer available irrelevant bare unavailability suffices even results prisoner deliberate strategy refraining filing timely grievance litigation prisoner claim begin federal key determining interpretations correct lies term art exhausted exhaustion important doctrine administrative habeas law therefore look bodies law guidance doctrine exhaustion administrative remedies well established jurisprudence administrative law mckart doctrine provides one entitled judicial relief supposed threatened injury prescribed administrative remedy exhausted ibid quoting myers bethlehem shipbuilding exhaustion administrative remedies serves two main purposes see mccarthy first exhaustion protects administrative agency authority ibid exhaustion gives agency opportunity correct mistakes respect programs administers haled federal discourages disregard agency procedures ibid second exhaustion promotes efficiency ibid claims generally resolved much quickly economically proceedings agency litigation federal cases claims settled administrative level others proceedings agency convince losing party pursue matter federal see ibid parisi davidson mckart supra even controversy survives administrative review exhaustion administrative procedure may produce useful record subsequent judicial consideration mccarthy supra advantages administrative review aggrieved parties voluntarily exhaust avenues administrative review resorting federal parties exhaustion requirement obviously unnecessary statutes requiring exhaustion serve purpose significant number aggrieved parties given choice voluntarily exhaust aggrieved parties may prefer exhaust administrative remedies variety reasons although exhaustion promotes overall efficiency party may conclude correctly incorrectly exhaustion efficient party particular case addition aggrieved parties may prefer proceed directly federal reasons including bad see thomas supra rosen dissenting part concurring judgment exhaustion requirements designed deal parties want exhaust administrative law creates incentive parties otherwise prefer namely give agency fair full opportunity adjudicate claims administrative law requiring proper exhaustion administrative remedies means using steps agency holds properly agency addresses issues merits pozo emphasis original described doctrine follows general rule courts topple administrative decisions unless administrative body erred erred objection made time appropriate practice tucker truck lines emphasis added see also sims apfel concurring part concurring judgment underlying principle administrative law unanimous breyer dissenting unemployment compensation alaska aragon hormel helvering davis pierce administrative law treatise pp ed proper exhaustion demands compliance agency deadlines critical procedural rules adjudicative system function effectively without imposing orderly structure course law habeas corpus rules substantively similar described habeas statute generally requires state prisoner exhaust state remedies filing habeas petition federal see rule comity reduces friction state federal systems avoiding liness federal district overturning conviction without state courts opportunity correct constitutional violation first instance boerckel alteration original state prisoner generally barred obtaining federal habeas relief unless prisoner properly presented claims one complete round state established appellate review process ibid practical terms law habeas like tive law requires proper exhaustion described feature habeas law follows integrity federal exhaustion rule ask whether prisoner exhausted state remedies also whether properly exhausted remedies citation omitted emphasis original law habeas however uses terminology differs administrative law habeas sanction failing exhaust properly preclusion review federal given separate name procedural default although habeas doctrines exhaustion procedural default similar purpose design implicate similar concerns keeney see also coleman thompson habeas remedies described exhausted longer available regardless reason unavailability see gray netherland thus remedies longer available prisoner failed comply deadline seeking review taking appeal remedies technically exhausted exhaustion sense automatically entitle habeas petitioner litigate claims federal instead petitioner procedurally defaulted claims prisoner generally barred asserting claims federal habeas proceeding coleman supra iii background mind persuaded plra exhaustion requirement requires proper exhaustion text strongly suggests plra uses term exhausted mean term means administrative law exhaustion means proper exhaustion section refers administrative remedies available thus points doctrine exhaustion administrative law construing require proper exhaustion also fits general scheme plra whereas respondent interpretation turn provision largely useless appendage plra attempts eliminate unwarranted interference administration thus seeks affor corrections officials time opportunity address complaints internally allowing initiation federal case nussle see also booth plra also intended reduce quantity improve quality prisoner suits nussle supra requiring proper exhaustion serves goals gives prisoners effective incentive make full use prison grievance process accordingly provides prisons fair opportunity correct errors particularly important relation state corrections systems difficult imagine activity state stronger interest one intricately bound state laws regulations procedures administration prisons preiser rodriguez proper exhaustion reduces quantity prisoner suits prisoners successful administrative process others persuaded proceedings file action federal finally proper exhaustion improves quality prisoner suits eventually filed proper exhaustion often results creation administrative record helpful grievance filed shortly event giving rise grievance witnesses identified questioned memories still fresh evidence gathered preserved requiring proper exhaustion serves purposes plra respondent interpretation make plra exhaustion scheme wholly ineffective benefits exhaustion realized prison grievance system given fair opportunity consider grievance prison grievance system opportunity unless grievant complies system critical procedural rules prisoner want participate prison grievance system little incentive comply system procedural rules unless noncompliance carries sanction respondent interpretation plra noncompliance carries significant sanction example prisoner wishing bypass available administrative remedies simply file late grievance without providing reason failing file time prison rejects grievance untimely prisoner proceed directly federal acceptance late grievance thwart prisoner wish bypass administrative process prisoner easily achieve violating procedural rules prison administration alternative dismiss grievance procedural grounds confident plra create toothless scheme respondent argues interpretation plra exhaustion provision filter frivolous claims time deadline filing grievance passed inmate may longer wish file suit brief respondent since deadline filing administrative grievance generally long days according see brief amicus curiae even less according respondent see brief respondent doubtful congress thought requiring prisoner wait long provide much deterrent indeed many prisoners probably find difficult prepare file serve civil complaint expiration deadline filing grievance many correctional systems respondent also contends interpretation plra exhaustion requirement filter frivolous claims prisoners simply wait deadline filing administrative grievance passed according respondent grievance systems give administrators discretion hear untimely grievances therefore prisoner required file untimely grievance thereby give grievance system opportunity address complaint assuming sake argument premise argument correct never conclude administrative remedies unavailable unless administrative decision held see coleman prisoner want participate prison grievance process little difficulty forcing prison dismiss administrative case procedural grounds california system example prisoner numerous opportunities miss deadlines therefore task engineering dismissal grievance procedural grounds unlikely sufficient alter conduct prisoner whose objective bypass administrative process finally interpreted respondent plra exhaustion requirement unprecedented respondent pointed statute case purports require exhaustion time allowing party bypass deliberately administrative process flouting agency procedural rules unlikely plra intended deal perceived disruptive tide frivolous prisoner litigation adopted exhaustion requirement goes model called attention permitting wholesale bypassing administrative remedies respondent identifies three models scheme exhaustion simpliciter believes set plra none examples apt respondent first looks habeas law existed prior wainwright sykes federal habeas claim procedurally defaulted prisoner deliberately bypassed state remedies see fay noia fanciful however suggest plra exhaustion requirement patterned habeas law existed years fay wainwright respondent stresses plra enacted contemporaneously antiterrorism effective death penalty act aedpa stat gave federal habeas review structure markedly different existed period fay wainwright furthermore respondent interpretation duplicate scheme existed habeas interval interpreted respondent permit prisoner bypass deliberately flagrantly administrative review without risk sanction unlikely plra intended permit two courts appeals held require proper exhaustion pointedly stated decisions allow prisoner bypass deliberately administrative remedies see thomas neither courts however explained interpreted way require proper exhaustion somehow proscribes deliberate bypass apparently recognizing interpretation neither statutory basis refers concept exhaustion existing body law respondent contend prohibits deliberate bypass view demands prisoner wait opportunity administrative review evaporated making argument respondent asks us hold plra meant adopt exhaustion scheme stands sharp contrast current past habeas law unlike exhaustion scheme called attention respondent next suggests plra exhaustion requirement patterned age discrimination employment act adea stat codified title vii civil rights act stat redesignated amended implausible models neither provisions makes reference concept exhaustion neither sense exhaustion provision oscar mayer evans considered adea provides state agency redress claims adea claim may brought federal expiration sixty days proceedings commenced state law emphasis added provision makes reference exhaustion state remedies commence ment state proceedings provision leaves doubt proper commencement proceedings required noted see oscar mayer adea requirement commencement satisfied merely sending state agency signed statement pertinent facts explicitly provides commencement requirement entail compliance state procedural rule including deadline initiating state proceeding see little similarity merely requires commencement state proceedings explicitly require timely commencement expressly requires exhaustion available administrative remedies reference federally based limiting principle section title vii also fundamentally different plra exhaustion provision interpreted means complainant initially institutes proceedings state local agency authority grant seek relief practice charged must file charge agency eeoc refer charge agency within days alleged discriminatory event eeoc commercial office products following reasoning oscar mayer held filing requirement demand charge submitted state local authority filed compliance authority time limit title vii refers filing charge state local agency exhaustion remedies viewed model plra exhaustion provision iv respondent remaining arguments regarding interpretation unconvincing relying use term phrase administrative remedies available exhausted respondent contends use temporal word conveys timing requirement assumes question answered simply whether prisoner file suit must wait later brief respondent likewise according respondent use present tense administrative remedies available emphasis added requires focus whether administrative remedies presently available saying party may sue federal party first pursues available avenues administrative review necessarily means party never pursues available avenues administrative review person never able sue federal thus use term present tense support respondent position respondent attaches significance fact plra exhaustion provision expressly state prisoner must properly exhausted available administrative remedies whereas tolling provision aedpa provides time filing federal habeas petition tolled period properly filed application state collateral review pending emphasis added view respondent draws unreasonable inference difference wording two provisions although aedpa plra enacted roughly time separate detailed pieces legislation moreover aedpa plra provisions deal separate issues tolling case aedpa exhaustion case plra respondent maintains interpretation plra exhaustion provision bolstered another plra provision permits district dismiss certain prisoner claims without first requiring exhaustion administrative remedies according respondent provision shows congress thought point district might make ruling typically well filing complaint prisoner might still opportunity exhaust administrative remedies short administrative filing deadlines make impossible respondent contends congress thought prisoner failure comply deadlines preclude litigation federal respondent argument unconvincing least two reasons first respondent shown congress reason believe every prison system relatively short categorical filing deadlines indeed respondent asserts grievance systems give administrators discretion hear untimely grievances second even dismissals typically occur opportunity pursue administrative remedies passed still serves useful function making clear plra exhaustion requirement jurisdictional thus allowing district dismiss plainly meritless claims without first addressing may much complex question namely whether prisoner fact properly exhaust available administrative respondent next argues similarity wording plra exhaustion provision aedpa exhaustion provision shows plra provision meant incorporate narrow technical definition exhaustion applies habeas reject argument two reasons first nothing particularly distinctive wording habeas plra exhaustion provisions say exhaustion provision must say judicial remedy may sought obtained unless certain remedies exhausted therefore unrealistic infer wording plra provision congress framed adopted provision habeas law administrative law mind indeed wording plra provision prisoner may bring action respect prison conditions administrative remedies available exhausted strikingly similar description doctrine administrative exhaustion one entitled judicial relief supposed threatened injury prescribed administrative remedy exhausted mckart citation omitted emphasis added second respondent suggestion plra meant incorporate technical distinction exists habeas law without providing sanction prevent willful noncompliance even deliberate bypass standard fay produce scheme practical terms radically different habeas scheme copying habeas narrow definition exhaustion without furnishing sanction promote compliance like copying design airplane omitting one wings respondent contends requiring proper exhaustion lead prison administrators devise procedural requirements designed trap unwary prisoners thus defeat claims respondent contend however anything like occurred case speculative occur future corrections officials concerned maintaining order institutions reason creating retaining grievance systems provide perceived prisoners providing meaningful opportunity prisoners raise meritorious grievances respect possibility prisons might create procedural requirements purpose tripping skillful prisoners congress repealed plain speedy effective standard see ed repealed occasion decide situations might addressed respondent argues requiring proper exhaustion harsh prisoners generally untrained law often poorly educated argument overlooks informality relative simplicity prison grievance systems like california well fact prisoners litigate federal generally proceed pro se forced comply numerous unforgiving deadlines procedural requirements reasons reverse judgment appeals ninth circuit remand case proceedings consistent opinion ordered jeanne woodford et petitioners viet mike ngo writ certiorari appeals ninth circuit june justice breyer concurring judgment agree enacting prison litigation reform act plra congress intended term exhausted mean term means administrative law exhaustion means proper exhaustion ante believe congress desired system prisoners elect bypass prison grievance systems without consequences administrative law however contains well established exceptions exhaustion see sims apfel breyer joined rehnquist scalia kennedy dissenting constitutional claims shalala illinois council long term care futility mckart hardship mccarthy madigan inadequate unavailable administrative remedies see generally ii pierce administrative law treatise ed moreover habeas corpus law contains exhaustion requirement substantively similar administrative law informs opinion ante also permits number exceptions see post stevens dissenting noting habeas corpus law permits petitioners overcome procedural defaults show procedural rule firmly established regularly followed demonstrate cause prejudice overcome procedural default enforcing procedural default rule result miscarriage justice citations omitted least two circuits interpreted statute manner similar today adopts concluded plra proper exhaustion requirement absolute see spruill gillis giano goord view remand lower similarly consider challenges petitioner may concerning whether case falls traditional exception statute implicitly incorporates jeanne woodford et petitioners viet mike ngo writ certiorari appeals ninth circuit june justice stevens justice souter justice ginsburg join dissenting citizen right access impartial tribunal seek redress official grievances fundamental well established sometimes taken granted state statute purported impose period limitations right discrete class litigants sue state official violation federal right obviously unenforceable federal question case whether enacting exhaustion requirement prison litigation reform act plra congress intended authorize state correction officials impose comparable limitation prisoners constitutionally protected right access federal courts text statute particularly read light jurisprudence provides us unambiguous negative answer common sense dictate congress enacted following exhaustion requirement plra action shall brought respect prison conditions section title federal law prisoner confined jail prison correctional facility administrative remedies available exhausted provision requires prisoners exhaust informal remedies filing lawsuit federal law must file administrative grievance resolution grievance unsatisfactory must exhaust available administrative appeals statute however says nothing reasons grievance may denied distinguish denial merits denial based procedural error attach significance prison official decision prisoner made procedural missteps exhausting administrative remedies words federal courts jurisprudence text plra impose waiver procedural default sanction upon prisoners make procedural errors see engle isaac explaining problem waiver separate question whether state prisoner exhausted state remedies plain text plra simply requires administrative remedies available exhausted prisoner take serious step filing federal lawsuit officials hold custody today however concludes plra exhaustion requirement requires proper exhaustion ante absence textual support conclusion sufficient reason rejecting unlike tolling provision antiterrorism effective death penalty act signed law two days plra lacks textual requirement proper exhaustion see artuz bennett explaining importance textual requirement application properly filed instead habeas context plra prisoner procedurally defaulted federal claims state prison grievance proceeding meets technical requirements exhaustion state remedies longer coleman thompson accordingly plain text respondent satisfied duty exhaust available administrative remedies filing federal lawsuit ii majority essentially ignores plra suggesting instead general administrative law principles allow courts certain circumstances impose procedural default sanctions matter federal common law suggest read waiver plra however discussed part iii infra cases make clear extratextual waiver sanctions appropriate statute directs federal act appellate tribunal directly reviewing decision federal agency actions brought rev stat respondent de novo proceedings federal district majority invocation principles seriously misguided majority disregard plain text plra especially unjustified light backdrop statute enacted presume course congress familiar precedents expects legislation interpreted conformity precedents see edelman lynchburg college porter nussle north star steel thomas strong presumption even forceful underlying precedent important gebser lago vista independent school quoting cannon university chicago consistent presumption already provided definitive interpretation language one statute congress uses nearly identical language another statute give language latter statute identical interpretation unless clear indication text legislative history see wells elementary principles statutory interpretation plra exhaustion requirement incorporate procedural default component solicitor general correctly points brief supporting petitioners plra exhaustion provision essentially identical habeas corpus statute brief amicus curiae specifically provision federal habeas statute first enacted codification previous bars relief unless appears applicant exhausted remedies available courts state plra similarly bars judicial relief administrative remedies available exhausted noteworthy distinction two provisions uses word unless whereas uses word anything distinction suggests exhaustion requirement plra less amenable waiver sanction comparable requirement habeas statute word indicates temporal condition whereas word unless appropriate procedural bar notwithstanding use word unless majority correctly recognizes held remedies exhausted purposes federal habeas statute long longer available regardless reason unavailability ante words exhaustion requirement federal habeas statute incorporate procedural default congress codification exhaustion requirement federal habeas law congress adoption essentially identical exhaustion requirement plra decided fewer six cases stated explicitly habeas petitioner satisfies statutory exhaustion requirement long remedies longer available time filing regardless reason unavailability see coleman teague lane engle fay noia rejects obvious analogy habeas law wording plra exhaustion provision also strikingly similar description doctrine administrative exhaustion one entitled judicial relief supposed threatened injury prescribed administrative remedy exhausted ante quoting mckart turn citing myers bethlehem shipbuilding language quoted majority case law indeed similar language plra habeas corpus statute provides help majority clearly used language describe exhaustion requirement procedural default sanction quoted language originally appeared justice brandeis opinion myers myers simple exhaustion case question presented whether employer seek immediate intervention federal courts response complaint filed national labor relations board engaged unfair labor practices whether await conclusion board proceedings avail judicial review case purely timing discussion whatever procedural default mckart clearly recognized language myers concerned exhaustion procedural default immediately quoting myers mckart discussed benefits exhaustion primarily avoiding premature interruption agency process drew analogy judicial rules limit interlocutory appeals without making reference procedural default see later opinion mckart turned discussion considerations underlying imposition procedural default sanction cases administrative process end party seeks judicial review decision appealed administrative process sum language majority quotes mckart supports presumption congress intended exhaustion requirement plra read conformity decisions interpreting exhaustion requirement federal habeas statute require exhaustion impose waiver sanction procedural errors made course exhaustion iii absent support procedural default sanction text plra turns background principles administrative law effort justify holding see ante discussion background administrative law principles misapprehends precedent general rule administrative law context courts administrative decisions unless administrative body erred erred objection made appropriate time practice ante quoting tucker truck lines doctrine like judicial doctrines subject numerous exceptions application doctrine specific cases requires understanding purposes particular administrative scheme involved mckart omitted see declining apply waiver doctrine circumstances case waiver doctrine administrative law largely creatur statute sims apfel words many statutes explicitly prohibit courts considering claims ha administrative agency quoting national labor relations act see tucker truck lines collecting statutes important emphasize statutory waiver requirements always mandate plain terms courts shall consider arguments properly raised agency never suggested word exhaustion standing alone imposes statutory waiver requirement accordingly claim procedural default sanction mandated simply interpreting applying statutory requirement set plra exhaustion provision ante patently erroneous federal administrative law context also imposed waiver requirements even absence explicit statutory directive rule discussed extensively majority see ante however based analogy rule appellate courts consider arguments raised trial courts sims analogy hold impose procedural default sanction see sims applying principles clear ordinary principles administrative law justify engrafting procedural default plra purpose action filed respondent obtain direct review order entered grievance procedure obtain redress alleged violation federal law committed state corrections officials see mitchum foster undisputed plra nothing change nature federal action prisoners bring actions exhausting administrative remedies entitled de novo proceedings federal district without deference issues law fact ruling administrative grievance proceedings sum federal district proceedings prison condition litigation bear resemblance appellate review lower decisions administrative law precedent cited majority makes clear engraft procedural default sanction majority misapprehension precedent especially troubling american bar association points particularly hesitant impose procedural technicalities statutory scheme laymen unassisted trained lawyers initiate process brief amicus curiae quoting oscar mayer evans finally majority invocation administrative law principles fails entirely separate reason established exception doctrine procedural default review administrative proceedings permits individuals raise constitutional complaints first time federal even failed raise claims properly agency sims respondent raised constitutional claims precedent may matter federal common law apply extrastatutory waiver requirement iv principal arguments offered support holding policy arguments view grounded purposes majority correctly identifies two principal purposes plra affording corrections officials time opportunity address complaints internally initiation federal lawsuit reducing quantity improving quality prison litigation purposes served plra even engraft procedural default sanction statute first policy concern identified majority even arguably justify either timeliness requirement procedural default sanction prison officials certainly opportunity address claims filed procedurally defective manner indeed california like vast majority state prison systems explicitly gives prison administrators opportunity hear untimely otherwise procedurally defective grievances cal code tit see generally roosevelt exhaustion prison litigation reform act consequence procedural error emory hereinafter roosevelt undisputed plra mandates prisoners exhaust administrative remedies filing federal lawsuit prison officials opportunity address prisoners claims suit second plra already effect reducing quantity prison litigation without need extrastatutory procedural default sanction petitioners point number civil rights suits filed prisoners federal dropped rate prisoner filing dropped even dramatically period prisoner suits per inmates suits per inmates contrast rate filing remained relatively constant dropping slight ly approximately suits per inmates see brief petitioners sharp drop prison litigation occurred seventh circuit opinion pozo mccaughtry first appellate decision engrafting procedural default sanction plra prior pozo federal courts regularly assumed plra create procedural default sanction dismissals failure exhaust without prejudice see roosevelt discussing cases thus plra including simple exhaustion requirement sufficient reduce quantity prisoner suits without procedural default requirement surprising exhaustion requirement always ensures prison officials opportunity address claims brought prisoners federal lawsuit prisoners successful administrative process others persuaded proceedings file action federal ante part fact heard mollify passions booth churner ordinary exhaustion also improves quality prisoner suits giving prison officials opportunity address prisoner grievance initiation lawsuit ordinary exhaustion often results creation administrative record helpful ante acknowledge course majority creation waiver sanction procedural missteps course exhaustion even significant effect reducing number lawsuits filed prisoners however legislation pursues purposes costs deciding competing values sacrificed achievement particular objective essence legislative choice frustrates rather effectuates legislative intent simplistically assume whatever furthers statute primary objective must law rodriguez per curiam emphasis deleted competing values congress sought effectuate enacting plra reducing number frivolous filings one hand preserving prisoners capacity file meritorious claims explained senator hatch introduced legislation senate floor plra needed quantity frivolous suits filed prisoners senator hatch view making difficult courts consider meritorious claims cong rec continued indeed want prevent inmates raising legitimate claims legislation prevent claims raised ibid similarly senator thurmond cosponsor bill stated plra allow meritorious claims filed gives judge broader discretion prevent frivolous malicious lawsuits filed prison inmates procedural default sanction created unlike exhaustion requirement created congress bars litigation random irrespective whether claim meritorious consider example inmate raped prison scenario far hypothetical enacting prison rape elimination act et seq supp iii congress estimated one million people sexually assaulted nation prisons last years although tragic incidents result constitutional violations sovereign constitutional duty provide humane conditions confinement farmer brennan accordingly inmates sexually assaulted guards whose sexual assaults inmates facilitated guards suffered grave deprivations eighth amendment rights yet engraftment procedural default sanction plra exhaustion requirement risks barring claims prisoner fails inter alia file grievance perhaps correctly fears within strict time requirements generally days nine much majority opinion seems assume absent creation waiver sanction prisoners purposely circumvent prison grievance proceedings however prisoners generally lack incentive capacity engage evasive tactics federal courts provide deference administrative decisions prison officials later federal suit de novo prisoners even prisoners acting bad faith lack incentive avoid filing administrative grievance unless fear retaliation moreover prisoners must exhaust administrative remedies prison officials always thwart efforts prisoners avoid grievance process simply exercising discretion excuse procedural defect presentation prisoners claims rate simple solution allow courts punish prisoners seek deliberately bypass state administrative remedies impose draconian punishment procedural default prisoners make reasonable efforts comply relevant administrative rules fear retaliation reasonable mistake law simple inadvertence make procedural misstep along way federal courts simply exercise discretion dismiss suits brought former group litigants brought latter majority argues imposing sanction prisoners deliberately bypass administrative remedies neither statutory basis refers concept exhaustion existing body law ante fact criticism applies majority engraftment overinclusive procedural default sanction plra insists upon rewriting light understanding statute purposes surely majority add statute harsher sanction making procedural error exhaustion necessary accomplish policy goals moreover ordinary abstention principles allow federal district courts dismiss suits brought prisoners deliberately bypassed available state remedies federal courts power decline jurisdiction exceptional circumstances including need promote wise judicial administration quackenbush allstate ins internal quotation marks omitted indeed fay emphasized discretion district judges embracing precisely deliberate bypass regime habeas corpus statute see applying deliberate bypass sanction plra ensure prisoners act bad faith penalized interfering capacity inmates litigate meritorious constitutional claims sum version plra congress actually enacted includes exhaustion requirement procedural default sanction plainly sufficient advance policy values identified moreover worries many prisoners act bad faith purposely eschew administrative remedies imposition deliberate bypass standard resolve problem without depriving litigants act good faith nonetheless make procedural error obtaining judicial relief relating valid constitutional claims majority holding unsupported policy concerns discusses text statute majority leaves open question whether prisoner failure comply properly procedural requirements provide meaningful opportunity prisoners raise meritorious grievances bar later filing suit federal ante majority mind meaningful opportunity unclear question sure breed great deal litigation federal courts years come example case respondent filed second grievance first grievance rejected arguing first grievance fact timely challenging petitioners continuing prohibition capacity participate catholic observances confession holy week services bible study prison rejected second grievance timeliness grounds even though denial respondent capacity engage religious activities clearly ongoing thus occurred within prison statute limitations see assuming respondent explicitly requested restoration right engage religious activities within days filing second grievance prison officials denied request petitioners grievance procedures fail provide respondent meaningful opportunity raise claim light continuing nature injury respondent challenging grievance fact timely cf klehr smith explaining clayton act overt act case continuing violation conspiracy sufficient restart statute limitations cases involving types procedural missteps limitations period furnish meaningful opportunity prisoner raise meritorious grievances context juvenile raped repeatedly assaulted knowledge assistance guards detention see minix pazera cv rm wl nd july prison grievance system provide meaningful opportunity women prisoners fail file timely grievances relating pattern rape sexual harassment throughout city prisons correctly fear retaliation file complaints see women prisoners district columbia supp dc remedies meaningful prisoner files grievance concerning prison official encouraged commit suicide prisoner reasonably thinks raises one claim prison officials interpret raise two separate claims one related guard comments one related prisoner failure receive health care thus dismiss violating prison regulation including one claim single grievance see harper laufenberg wl wd prison officials dismiss timely filed appeal prisoner explains prison take two weeks finish making certain copies relevant documents sending letter secretary department corrections rather secretary inmate grievances appeals prison regulations see keys craig fed appx per curiam generally remedies meaningful prison officials refuse hear claim simply prisoner makes hypertechnical procedural error see spruill gillis imposing procedural default sanction plra stating compliance grievance proceedings need giano goord stating failure comply procedural requirements grievance proceedings may excused based special circumstances prisoner reasonable mistaken understanding prison regulations depending answer questions like majority interpretation plra may cause statute vulnerable constitutional challenges right access courts aspect first amendment right petition government redress grievances bill johnson restaurants nlrb accordingly constitution guarantees prisoners like citizens reasonably adequate opportunity raise constitutional claims impartial judges see lewis casey moreover access courts fundamental right see classifications impose substantial burdens capacity group citizens exercise right require searching judicial examination equal protection clause see lyng automobile workers correct interpretation plra obviate need litigation issues important correct interpretation statute recognize enacting plra members congress created rational regime designed reduce quantity frivolous prison litigation adhering constitutional duty respect dignity persons even convicted heinous crimes roper simmons today decision ignores duty respectfully dissent footnotes one conceive inmate seeking avoid creating administrative record someone views hostile factfinder filing lawsuit primarily method making corrections official life difficult perhaps even speculating suit mean welcome temporary respite cell dissent makes two chief arguments regarding doctrine exhaustion administrative law neither sound first dissent contends absence explicit statutory directive proper exhaustion required proceedings nature appellate review proceedings post opinion stevens authorities cited support proposition sims apfel concerns different questions issue exhaustion distinction adversarial proceedings amici brief turns cites supporting authority see post citing brief law professors amici brief argues conceptual key case distinction original proceeding simply determining legality action review proceeding must review decision adjudicator according amici brief habeas petitions prime examples review proceeding ask federal courts review decisions state courts argument deeply flawed abeas corpus original civil remedy enforcement right personal liberty rather stage state criminal proceedings appeal therefrom fay noia omitted habeas law includes doctrine procedural default post shows dissent amici brief incorrect contending proper exhaustion requirement incompatible original proceeding second dissent argues even administrative law generally requires proper exhaustion respondent falls within exception rule post dissent puts ecause respondent raised constitutional claims may matter federal common law apply extrastatutory waiver requirement ibid applying extrastatutory requirement matter federal common law ibid interpreting applying statutory requirement set plra exhaustion provision interpret plra exhaustion provision require proper exhaustion unprecedented scheme exhaustion simpliciter respondent advocates suggestion plra might meant require proper exhaustion claims constitutional claims fail see serve congress purpose addressing flood prisoner litigation federal courts see supra overwhelming majority prisoner civil rights prison condition suits based constitution see termination consent decrees dissent objection post exhaustion simpliciter enough reduce frivolous prisoner suits well taken first matters whether proper exhaustion necessary reach goal whether proper exhaustion mandated congress second empirical support dissent conclusion weak dissent points drop volume prisoner litigation concludes clearly direct result plra exhaustion requirement post mistakes correlation causation requirement exhaustion simpliciter absent mollified prisoner prevent case docketed thus appearing filing statistics dissent cites credit reduced filings likely belongs plra enactment requiring district courts screen docketing feasible prisoner civil complaints amendments forbidding prisoners proceeding forma pauperis finally prisoner civil rights prison conditions cases still account outsized share filings cases represented new filings federal district courts average one new prisoner case every week nearly active senior district judges across country see administrative office courts judicial facts figures tbls http visited june available clerk case file questions regarding timeliness prisoner filings occur frequently see wallace burbury supp nd ohio pusey belanger civ wl eakle tennis civ wl md williams briley wl nd june issac nix civ wl nd mar footnotes used term waiver referring sanction habeas corpus context use term opinion strictly speaking accurate characterize sanction forfeiture sanction question prisoners making procedural error course exhausting administrative remedies purposefully relinquish right bring constitutional claims federal majority claim plain language statute dictates decision rather text strongly suggests plra includes procedural default sanction ante majority section refers administrative remedies available thus points doctrine exhaustion administrative law ibid reference administrative remedies simply addresses fact review procedures provided prison officials administrative character rather judicial rate discussed part iii infra doctrine exhaustion administrative law support majority engraftment procedural default sanction plra see generally boerckel stevens joined ginsburg breyer dissenting tracing history exhaustion requirement habeas law language relevant part identical language enacted see stat habeas law separate doctrine procedural default stemming decision wainwright sykes may bar relief even though claim exhausted procedural default doctrine based unique considerations comity habeas context including need ensure state criminal trial remains main event rather tryout road later federal habeas proceeding internal quotation marks omitted moreover procedural default habeas closely related principle lacks certiorari jurisdiction review judgment rests adequate independent state procedural ground see undisputed unique considerations apply context suits purpose interpose federal courts people guardians people federal rights mitchum foster accordingly majority correctly suggest incorporate procedural default jurisprudence federal habeas context prison conditions suits nonetheless fear majority analysis may actually create harsher procedural default regime plra procedural default doctrine habeas law see muhammad close per curiam stating risoners suing generally face substantially lower gate prisoners seeking habeas corpus relief even requirement prison litigation reform act administrative opportunities exhausted first citing habeas jurisprudence allows petitioners overcome procedural defaults show procedural rule firmly established regularly followed see james kentucky demonstrate cause prejudice overcome procedural default enforcing procedural default rule result miscarriage justice see murray carrier majority attempt distinguish sims concerning different questions ante perplexing particularly light fact brief supporting petitioners relies sims argue administrative law decisions support proposition impose waiver sanction plra see brief amicus curiae although particular procedural error made exhaustion administrative remedies different sims procedural error issue analysis sims concerned circumstances engraft waiver sanction administrative exhaustion process generally see concurring part concurring judgment breyer dissenting majority suggestion habeas law indicates otherwise see ante incorrect explained see supra procedural default sanction habeas law based unique considerations apply suits precedent concerning judicial review administrative proceedings upon majority purports rely see ante makes clear impose waiver sanction judicial review administrative decision resemble appellate review lower decisions majority notes many prisoners proceed pro se federal also time limits procedural requirements see ante however timeliness procedural requirements prison grievance systems generally far stringent imposed federal courts see brief american civil liberties union et al amici curiae brief jerome frank legal services organization yale law school amicus curiae course majority serious matters whether proper exhaustion necessary reach policy goals whether proper exhaustion mandated congress ante opinion rest almost entirely policy arguments regard majority reference coleman thompson see ante perplexing prison regulation explicitly grants prison officials discretion consider untimely otherwise procedurally defective grievances course prison grievance remedies still available thus unexhausted prisoner even tried file grievance simply untimely otherwise procedurally defective without support majority speculates drop suits filed prisoners resulted provisions plra see ante regardless aforementioned statistics demonstrate procedural default sanction imposed plra unnecessary reduce quantity prison litigation majority also argues ensuring strict compliance strict prison timeliness requirements generally ranging hours month see infra improve quality prisoner litigation grievance filed shortly event giving rise grievance witnesses identified questioned memories still fresh evidence gathered preserved ante advantages filing grievances soon alleged injury occurs courts regularly resolve litigation without draconian time limitations rate discussed legislation pursue one purpose costs marginal advantages encouraging compliance short time limitations justify judicially rewriting plra exhaustion requirement engrafting procedural default sanction statute indeed anything worse effect meritorious claims prisoners file frivolous claims probably likely repeat filers learn ins outs procedural requirements see daskalea district columbia cadc discussing female prisoner underwear confiscated placed solitary confinement without mattress result talking prison officials sexual assaults harassment guards subjected comprehensive discussion state prison grievance system filing deadlines see brief american civil liberties union et al amici curiae brief jerome frank legal services organization yale law school amicus curiae