Booth v. Churner

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Booth v. Churner
Seal of the United States Supreme Court.svg
Argued March 20, 2001
Decided May 29, 2001
Full case nameTimothy Booth, v. C.O. Churner, et al.
Citations532 U.S. 731 ( more )
121 S. Ct. 1819; 149 L. Ed. 2d 958
Case history
PriorComplaint 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
Chief Justice
William Rehnquist
Associate Justices
John P. Stevens  · Sandra Day O'Connor
Antonin Scalia  · Anthony Kennedy
David Souter  · Clarence Thomas
Ruth Bader Ginsburg  · Stephen Breyer
Case opinion
MajoritySouter, 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.

Supreme Court of the United States Highest court in the United States

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.

Contents

Background

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.

Injunction a legal order to stop doing something

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.

Opinion of the Court

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 Souter American judge

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.

See also

Eighth Amendment to the United States Constitution prohibits cruel and unusual punishment and excessive bail

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.

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References

  1. 1 2 532 U.S. at 735.
  2. 532 U.S. at 734-736.
  3. 532 U.S. at 733.
  4. 532 U.S. at 741.
  5. 1 2 532 U.S. at 740.

Further reading

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.