Alexander S. v. Boyd

In Alexander S. v. Boyd, 113 F.3d 1373, 1383 (4th Cir.1997), a case with facts similar to the present case, the Fourth Circuit determined that the definition of "jail, prison, or other correctional facility" covered the juvenile facility at issue in that case. 113 F.3d at 1383-84. The court stated that since 18 U.S.C. 3626(g)(5) and 42 U.S.C. 1997e(d)(1) were enacted at the same time as part of the Prison Litigation Reform Act ("PLRA"), the definitions of "prison" are the same, based on the "cardinal rule of statutory construction ... that statutes which are originally part of the same Act should be construed together." Id. Therefore, "jail, prison, or other correctional facility" in 42 U.S.C. 1997e(d)(1) encompasses juvenile facilities since 18 U.S.C. 3626(g)(5) defines prisons to include juvenile facilities. Id. at 1384.