Booth v. Churner

In Booth v. Churner (2001) 149 L. Ed. 2d 958, 532 U.S. 731, the United States Supreme Court rejected a similar contention and held that the PLRA requires administrative exhaustion even where the grievance process does not permit an award of money damages and the prisoner seeks only money damages, as long as the grievance tribunal has authority to take some responsive action. The Supreme Court explained that "before section 1997e(a) was amended by the PLRA of 1995, a court had discretion (though no obligation) to require a state inmate to exhaust 'such . . . remedies as are available,' but only if those remedies were 'plain, speedy, and effective.' That scheme, however, is now a thing of the past, for the amendments eliminated both the discretion to dispense with administrative exhaustion and the condition that the remedy be 'plain, speedy, and effective' before exhaustion could be required." ( Booth, supra, 532 U.S. 121 S. Ct. at p. 1824.) The Booth court reasoned that, "Congress's imposition of an obviously broader exhaustion requirement makes it highly implausible that it meant to give prisoners a strong inducement to skip the administrative process simply by limiting prayers for relief to money damages not offered through administrative grievance mechanisms." (Id. 121 S. Ct. at p. 1825.)