Booth v. Churner | |
---|---|
Argued March 20, 2001 Decided May 29, 2001 | |
Full case name | Timothy Booth, v. C.O. Churner, et al. |
Citations | 532 U.S. 731 ( more ) 121 S. Ct. 1819; 149 L. Ed. 2d 958 |
Case history | |
Prior | Complaint dismissed (M.D. Pa., 1997); affirmed, 206 F.3d 289 (3d Cir. 2000) |
Holding | |
Prisoners who seek only monetary damages in suits over prison conditions still must exhaust all administrative remedies before going to court, even if monetary damages are not available under the particular administrative process. | |
Court membership | |
| |
Case opinion | |
Majority | Souter, joined by unanimous |
Laws applied | |
Prison Litigation Reform Act of 1995 |
Booth v. Churner, 532 U.S. 731 (2001), was a United States Supreme Court case decided in 2001. The case concerned the extent to which a state prisoner must first utilize an administrative review process provided by the state, prior to filing a case in federal district court. The Court held that Booth still had a mechanism of administrative review, and thus his claim was premature.
The Supreme Court of the United States (SCOTUS) is the highest court in the federal judiciary of the United States. It has ultimate appellate jurisdiction over all federal and state court cases that involve a point of federal law, and original jurisdiction over a narrow range of cases, including suits between two or more states and those involving ambassadors. The Court holds the power of judicial review, the ability to invalidate a statute for violating a provision of the U.S. Constitution. It is also able to strike down presidential directives for violating either the Constitution or statutory law. However, it may act only within the context of a case in an area of law over which it has jurisdiction. The Court may decide cases having political overtones, but it has ruled that it does not have power to decide non-justiciable political questions.
The Prison Litigation Reform Act of 1995 requires a prisoner to exhaust "such administrative remedies as are available" before suing over prison conditions. [1] Timothy Booth, an inmate at the State Correctional Institution at Smithfield, Pennsylvania, filed a suit in District Court, claiming that corrections officers violated his Eighth Amendment right to be free from cruel and unusual punishment. Booth sought both injunctive relief and monetary damages. At the time of Booth's suit, Pennsylvania provided an administrative grievance and appeals system, which addressed Booth's complaints but had no provision for recovery of money damages. [2] After the prison authority denied his administrative grievance, Booth did not seek administrative review. Subsequently, the District Court dismissed the complaint for failure to exhaust administrative remedies. In affirming, the Third Circuit Court of Appeals rejected Booth's argument that the exhaustion requirement was inapplicable because the administrative process could not award him the monetary relief he sought. [1]
Cruel and unusual punishment is a phrase describing punishment that is considered unacceptable due to the suffering, pain, or humiliation it inflicts on the person subjected to it.
An injunction is a legal and equitable remedy in the form of a special court order that compels a party to do or refrain from specific acts. "When a court employs the extraordinary remedy of injunction, it directs the conduct of a party, and does so with the backing of its full coercive powers." A party that fails to comply with an injunction faces criminal or civil penalties, including possible monetary sanctions and even imprisonment. They can also be charged with contempt of court. Counterinjunctions are injunctions that stop or reverse the enforcement of another injunction.
He appealed to the United States Supreme Court, which agreed to hear his case. The attorneys general of over 30 states filed amicus curiae briefs at the Court, urging affirmance of the decision. [3]
Certiorari is a court process to seek judicial review of a decision of a lower court or administrative agency. The term comes from the name of an English prerogative writ, issued by a superior court to direct that the record of the lower court be sent to the superior court for review.
An amicus curiae is someone who is not a party to a case and may or may not have been solicited by a party and who assists a court by offering information, expertise, or insight that has a bearing on the issues in the case; and is typically presented in the form of a brief. The decision on whether to consider an amicus brief lies within the discretion of the court. The phrase amicus curiae is legal Latin.
Justice David Souter wrote the unanimous majority opinion of the court, which agreed with the Third Circuit in rejecting Booth's claims. [4] The Court held that even though the prison grievance procedure did not provide for requested monetary relief, Booth was nonetheless required to exhaust administrative remedies before filing suit with respect to prison conditions. [5] Justice Souter wrote for the Court, "we think that Congress has mandated exhaustion clearly enough, regardless of the relief offered through administrative procedures." [5] Therefore, Booth's suit was premature.
David Hackett Souter is a retired Associate Justice of the Supreme Court of the United States. He served from October 1990 until his retirement in June 2009. Appointed by President George H. W. Bush to fill the seat vacated by William J. Brennan Jr., Souter sat on both the Rehnquist and Roberts Courts.
In law, a majority opinion is a judicial opinion agreed to by more than half of the members of a court. A majority opinion sets forth the decision of the court and an explanation of the rationale behind the court's decision.
The Eighth Amendment of the United States Constitution prohibits the federal government from imposing excessive bail, excessive fines, or cruel and unusual punishments. This amendment was adopted on December 15, 1791, along with the rest of the United States Bill of Rights. The phrases in this amendment originated in the English Bill of Rights of 1689.
A lawsuit is a proceeding by a party or parties against another in the civil court of law. The archaic term "suit in law" is found in only a small number of laws still in effect today. The term "lawsuit" is used in reference to a civil action brought in a court of law in which a plaintiff, a party who claims to have incurred loss as a result of a defendant's actions, demands a legal or equitable remedy. The defendant is required to respond to the plaintiff's complaint. If the plaintiff is successful, judgment is in the plaintiff's favor, and a variety of court orders may be issued to enforce a right, award damages, or impose a temporary or permanent injunction to prevent an act or compel an act. A declaratory judgment may be issued to prevent future legal disputes.
A declaratory judgment, also called a declaration, is the legal determination of a court that resolves legal uncertainty for the litigants. It is a form of legally binding preventive adjudication by which a party involved in an actual or possible legal matter can ask a court to conclusively rule on and affirm the rights, duties, or obligations of one or more parties in a civil dispute. The declaratory judgment is generally considered a statutory remedy and not an equitable remedy in the United States, and is thus not subject to equitable requirements, though there are analogies that can be found in the remedies granted by courts of equity. A declaratory judgment does not by itself order any action by a party, or imply damages or an injunction, although it may be accompanied by one or more other remedies.
Seminole Tribe of Florida v. Florida, 517 U.S. 44 (1996), was a United States Supreme Court case which held that Article One of the U.S. Constitution did not give the United States Congress the power to abrogate the sovereign immunity of the states that is further protected under the Eleventh Amendment. Such abrogation is permitted where it is necessary to enforce the rights of citizens guaranteed under the Fourteenth Amendment as per Fitzpatrick v. Bitzer. The case also held that the doctrine of Ex parte Young, which allows state officials to be sued in their official capacity for prospective injunctive relief, was inapplicable under these circumstances, because any remedy was limited to the one that Congress had provided.
Bivens v. Six Unknown Named Agents, 403 U.S. 388 (1971), was a case in which the US Supreme Court ruled that an implied cause of action existed for an individual whose Fourth Amendment freedom from unreasonable search and seizures had been violated by the Federal Bureau of Narcotics. The victim of such a deprivation could sue for the violation of the Fourth Amendment itself despite the lack of any federal statute authorizing such a suit. The existence of a remedy for the violation was implied by the importance of the right violated.
The United States Court of Federal Claims is a United States federal court that hears monetary claims against the U.S. government. It is the direct successor to the United States Court of Claims, which was founded in 1855, and is therefore a revised version of one of the oldest federal courts in the country.
The doctrine of exhaustion of remedies prevents a litigant from seeking a remedy in a new court or jurisdiction until all claims or remedies have been exhausted in the original one. The doctrine was originally created by case law based on the principles of comity.
Chauffeurs, Teamsters, and Helpers Local No. 391 v. Terry, 494 U.S. 558 (1990), was a case in which the United States Supreme Court held that an action by an employee for a breach of a labor union's duty of fair representation entitled him to a jury trial under the Seventh Amendment.
Woodford v. Ngo, 548 U.S. 81 (2006), is a United States Supreme Court case about the procedures determining when prison litigation may be commenced in federal court. Justice Samuel Alito, writing for the majority, ruled that prisoners must exhaust all state-court remedies in accordance with the rules thereof before filing claims in federal court. Justice Stephen Breyer filed a concurrence. Justice John Paul Stevens filed a dissent.
Nevada Department of Human Resources v. Hibbs, 538 U.S. 721 (2003), was a United States Supreme Court case which held that the Family and Medical Leave Act of 1993 was "narrowly targeted" at "sex-based overgeneralization" and was thus a "valid exercise of [congressional] power under Section 5 of the Fourteenth Amendment."
Darby v. Cisneros, 509 U.S. 137 (1993), was a case in which the United States Supreme Court held that federal courts cannot require that a plaintiff exhaust his administrative remedies before seeking judicial review when exhaustion of remedies is not required by either administrative rules or statute.
Lexecon Inc. v. Milberg Weiss Bershad Hynes & Lerach, 523 U.S. 26 (1998), was a United States Supreme Court case in which the Court unanimously held that a district court conducting coordinated pretrial proceedings in multiple cases by designation of the Judicial Panel on Multidistrict Litigation under 28 U.S.C. § 1407(a) has no authority to reassign a transferred case to itself for the actual trial of the case. The Court's decision overturned numerous lower-court decisions upholding what had become a common practice in multi-district cases.
The Prison Litigation Reform Act (PLRA), 42 U.S.C. § 1997e, is a U.S. federal law that was enacted in 1996. Congress enacted PLRA in response to a significant increase in prisoner litigation in the federal courts; the PLRA was designed to decrease the incidence of litigation within the court system.
Jones v. Bock, 549 U.S. 199 (2007), was a case before the United States Supreme Court. The issues concerned obligations of inmate litigants before one could file a civil rights action. The majority opinion was by Chief Justice Roberts and the court decided the case unanimously.
Plata v. Schwarzenegger, docket no. 3:01-cv-01351-TEH, is a federal class action civil rights lawsuit alleging that the California Department of Corrections and Rehabilitation's (CDCR) medical services are inadequate and violate the Eighth Amendment, the Americans with Disabilities Act, and section 504 of the Rehabilitation Act of 1973. As a result of the case, the CDCR's prison medical conditions were found to be in violation of the Eighth Amendment to the United States Constitution. After repeated violations of a stipulated agreement and order for injunctive relief, the CDCR was held in civil contempt and the medical health care system was placed in receivership.
Porter v. Nussle, 534 U.S. 516 (2002), is a United States Supreme Court case in which the court settled an intercircuit conflict regarding civil procedure for prisoners seeking redress. The court held that prisoners alleging assaults by prison guards must meet §1997e(a)'s exhaustion requirement before commencing a civil rights action.
United States v. White Mountain Apache Tribe, 537 U.S. 465 (2003), was a case in which the Supreme Court of the United States held in a 5–4 decision that when the federal government used land or property held in trust for an Indian tribe, it had the duty to maintain that land or property and was liable for any damages for a breach of that duty. In the 1870s, the White Mountain Apache Tribe was placed on a reservation in Arizona. The case involved Fort Apache, a collection of buildings on the reservation which were transferred to the tribe by the United States Congress in 1960.
Microsoft Corp. v. Motorola Inc., 696 F.3d 872 was a United States Court of Appeals for the Ninth Circuit case about Reasonable and Non-Discriminatory (RAND) Licensing and foreign anti-suit injunction.
Felder v. Casey, 487 U.S. 131 (1988), was a United States Supreme Court case that held that a state notice-of-claim statute could not be applied to a civil rights suit under 42 U.S.C. § 1983 in state court.
Ross v. Blake, 578 U.S. ___ (2016), was a United States Supreme Court case in which the Court held that "special circumstances" cannot excuse an inmate's failure to exhaust administrative remedies before filing a lawsuit under the Prison Litigation Reform Act of 1995, but clarified that inmates are required to exhaust only administrative remedies that are genuinely available. In so doing, it vacated and remanded the decision of the United States Court of Appeals for the Fourth Circuit.
Fry v. Napoleon Community Schools, 580 U.S. ___ (2017), is a United States Supreme Court case in which the Court held that the Handicapped Children's Protection Act of 1986 does not command exhaustion of state-level administrative remedies codified in the Individuals with Disabilities Education Act (IDEA) when the gravamen of the plaintiff's lawsuit is not related to the denial of free appropriate public education (FAPE).
The University of Pennsylvania Law Review is a law review focusing on legal issues, published by an organization of second and third year J.D. students at the University of Pennsylvania Law School. It is the oldest law journal in the United States, having been published continuously since 1852. Currently, seven issues are published each year with the last issue traditionally featuring papers from symposia held by the review each year. It is one of the four law reviews responsible for publication of the Bluebook. It is one of five official scholarly journals at the University of Pennsylvania Law School, and the third-most-cited law journal in the world.