## Facts

- Ronald Nussle, a Connecticut inmate at Cheshire Correctional Institution, alleged that several correction officers removed him from his cell and assaulted him by striking him, kneeing him, and pulling his hair.
- Nussle alleged the assault was unprovoked and that officers threatened to kill him if he reported it.
- Near the end of the limitations period, Nussle filed a federal civil-rights action under 42 U.S.C. § 1983 alleging Eighth Amendment violations based on harassment, intimidation, and a severe beating.
- Nussle did not pursue the prison’s administrative grievance process before filing suit.
- The Prison Litigation Reform Act (PLRA), 42 U.S.C. § 1997e(a), provides that no action “with respect to prison conditions” may be brought under § 1983 or other federal law until “such administrative remedies as are available are exhausted.”

## Issues

1. Whether the PLRA’s exhaustion requirement in 42 U.S.C. § 1997e(a) applies to prisoner suits alleging a single episode of excessive force by correctional officers.
2. Whether “action[s] … brought with respect to prison conditions” covers only general conditions affecting prisoners as a group, or also particular episodes affecting an individual prisoner.

## Decision

- The Supreme Court unanimously reversed the court of appeals.
- The Court held that § 1997e(a) requires exhaustion for all inmate suits about prison life, whether they concern general circumstances or particular episodes, including excessive-force allegations.
- Because Nussle did not exhaust available administrative remedies, his federal action could not proceed as filed; the case was remanded for further proceedings consistent with the Court’s ruling.

## Legal Principles

- Exhaustion under 42 U.S.C. § 1997e(a) is mandatory, not discretionary, when administrative remedies are available.
- “Prison conditions” in § 1997e(a) includes all inmate suits about prison life, covering both systemic conditions and single-incident misconduct such as alleged guard assaults.
- A prisoner must exhaust available administrative remedies even when the claim seeks relief that the administrative process may not provide.
- The exhaustion requirement serves to permit internal resolution, filter out meritless claims, and improve the quality of litigation that proceeds to federal court.

## Conclusion

The Court held that the PLRA’s exhaustion requirement applies to every prisoner suit concerning prison life, including individual excessive-force incidents, and therefore a prisoner must exhaust available administrative remedies before bringing such claims in federal court.


Porter v. Nussle, 534 U.S. 516 (2002)