## Facts

- Michigan prisoners filed federal civil rights suits under 42 U.S.C. § 1983 against Michigan Department of Corrections officials alleging unconstitutional prison conditions and related misconduct.
- The suits were subject to the Prison Litigation Reform Act (PLRA), which requires exhaustion of available administrative remedies before filing federal actions about prison conditions.
- The prisoners used the prison grievance system but did not obtain relief and then sued in federal court.
- Lower courts dismissed claims or defendants based on three Sixth Circuit exhaustion rules: (1) prisoners must plead and prove exhaustion in the complaint, (2) prisoners may sue only defendants named in the grievance, and (3) any unexhausted claim required dismissal of the entire action.

## Issues

1. Whether PLRA nonexhaustion is an affirmative defense or a pleading requirement that prisoners must satisfy in the complaint.
2. Whether “proper exhaustion” under the PLRA requires a grievance to name every later-sued defendant.
3. Whether the PLRA requires “total exhaustion,” mandating dismissal of an entire action if any claim is unexhausted.

## Decision

- The Court unanimously rejected the Sixth Circuit’s three judge-made exhaustion rules as not required by the PLRA.
- Failure to exhaust under the PLRA is an affirmative defense; prisoners need not plead or demonstrate exhaustion in the complaint.
- The PLRA does not impose a “name-all-defendants” requirement; compliance is measured by the prison’s grievance rules.
- The PLRA does not require total exhaustion; courts should dismiss only unexhausted claims and allow exhausted claims to proceed.

## Legal Principles

- PLRA exhaustion is mandatory, but nonexhaustion is an affirmative defense ordinarily raised and proved by defendants under the Federal Rules.
- Federal pleading rules generally do not require plaintiffs to plead around affirmative defenses absent statutory or rules-based direction.
- “Proper exhaustion” is defined by the prison’s own grievance procedures (including required specificity), not by additional judicially created requirements.
- When a complaint includes both exhausted and unexhausted claims, the proper remedy is claim-by-claim dismissal of unexhausted claims, not dismissal of the entire action.

## Conclusion

The Court held that the PLRA does not alter ordinary federal pleading allocations by requiring prisoners to plead exhaustion, does not require grievances to name every later-sued defendant unless prison rules demand it, and does not compel dismissal of exhausted claims merely because other claims were unexhausted.


Jones v. Bock, 549 U.S. 199 (2007)