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Woodford v. Ngo
United States Supreme Court
548 U.S. 81 (2006)
Facts
Viet Mike Ngo (plaintiff) was a prisoner in California serving a life sentence for murder. Jeanne Woodford (defendant), a correctional officer, prohibited Ngo from attending religious activities because Ngo was caught acting inappropriately in the prison chapel. California’s department of corrections had a three-step administrative process for resolving grievances, which required a prisoner to file a complaint within 15 days of the relevant action being challenged. Ngo complained more than 15 days after being restricted from religious activities, so the department of corrections denied Ngo’s complaint as untimely. Ngo sued Woodford under 42 U.S.C. § 1983. The district court granted Woodford’s motion to dismiss because the Prison Litigation Reform Act (PLRA) required a prisoner to exhaust their available administrative remedies before filing suit in federal court. The Court of Appeals for the Ninth Circuit reversed, holding that at the time Ngo filed suit, no administrative remedies were available to him, so Ngo was automatically held to have exhausted all available administrative remedies. The Supreme Court granted certiorari to determine whether Ngo had exhausted his available administrative remedies.
Rule of Law
Issue
Holding and Reasoning (Alito, J.)
Concurrence (Breyer, J.)
Dissent (Stevens, J.)
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