Woodford v. Ngo, 548 U.S. 81 (2006)

In Woodford v. Ngo, the underlying dispute arose from a California prison inmate, Viet Mike Ngo, who filed a lawsuit alleging that prison officials violated his constitutional rights. Specifically, Ngo claimed that he was subjected to cruel and unusual punishment due to the conditions of his confinement. Before pursuing his claim in federal court, Ngo was required to exhaust all available administrative remedies as mandated by the Prison Litigation Reform Act (PLRA). However, he submitted an administrative grievance that was deemed untimely and procedurally defective, which led to questions about whether he had properly exhausted his administrative remedies. The procedural history of the case began when the district court dismissed Ngo's lawsuit, ruling that he had not exhausted his administrative remedies as required by the PLRA. Ngo appealed this decision to the Ninth Circuit Court of Appeals, which reversed the district court's ruling. The Ninth Circuit held that the PLRA's exhaustion requirement could be satisfied even if the grievance was not timely or was otherwise defective. The case was subsequently brought before the Supreme Court on a writ of certiorari to resolve the conflicting interpretations of the exhaustion requirement under the PLRA. The relevant background context includes the enactment of the PLRA in 1996, which aimed to reduce the number of frivolous prisoner lawsuits by imposing a strict exhaustion requirement. This law mandated that prisoners must exhaust all available administrative remedies before filing a lawsuit, regardless of whether the administrative process could grant the relief sought. The case highlighted the importance of adhering to procedural rules within prison grievance systems, as well as the implications of the PLRA on prisoners' access to the courts.

Whether a prisoner can satisfy the Prison Litigation Reform Act’s exhaustion requirement by filing an untimely or otherwise procedurally defective administrative grievance or appeal.

The judgment is reversed and remanded.