Porter v. Nussle
Encyclopedia
Porter v. Nussle, , is a United States Supreme Court
case in which the court settled an intercircuit conflict regarding civil procedure
for prisoners seeking redress. The court held that prisoners alleging assaults by prison guards must meet §1997e(a)'s exhaustion requirement before commencing a civil rights action.
, asserted that, on or about June 15, 1996, several correctional officers asked him to leave his cell, "placed him against a wall and struck him with their hands, kneed him in the back, [and] pulled his hair." Nussle alleged that the attack was unprovoked and unjustified, and that the officers told him they would kill him if he reported the beating.
Without filing a grievance through the Connecticut Department of Correction
, on June 10, 1999, Nussle commenced an action in federal district court under 42 U. S. C. §1983; he filed suit days before the three-year statute of limitations ran out on the §1983 claim. Nussle charged, principally, that the corrections officers' assault violated his right to be free from cruel and unusual punishment
under the Eighth Amendment
, as made applicable to the States by the Fourteenth Amendment
. The District Court
, relying on §1997e(a), dismissed Nussle's complaint for failure to exhaust administrative remedies.
Construing §1997e(a) narrowly because it is an exception "to the general rule of non-exhaustion in §1983 cases," the Court of Appeals for the Second Circuit
reversed the District Court's judgment; the appeals court held that "exhaustion of administrative remedies is not required for [prisoner] claims of assault or excessive force brought under §1983." Section 1997e(a) requires administrative exhaustion of inmates' claims "with respect to prison conditions," but contains no definition of the words "prison conditions." The appeals court found the term "scarcely free of ambiguity." In conflict with the Second Circuit, other Federal Courts of Appeals
have determined that prisoners alleging assaults by prison guards must meet §1997e(a)'s exhaustion requirement before commencing a civil rights action.
Supreme Court of the United States
The Supreme Court of the United States is the highest court in the United States. It has ultimate appellate jurisdiction over all state and federal courts, and original jurisdiction over a small range of cases...
case in which the court settled an intercircuit conflict regarding civil procedure
Civil procedure
Civil procedure is the body of law that sets out the rules and standards that courts follow when adjudicating civil lawsuits...
for prisoners seeking redress. The court held that prisoners alleging assaults by prison guards must meet §1997e(a)'s exhaustion requirement before commencing a civil rights action.
Background
Ronald Nussle, an inmate at the Cheshire Correctional Institution in ConnecticutConnecticut
Connecticut is a state in the New England region of the northeastern United States. It is bordered by Rhode Island to the east, Massachusetts to the north, and the state of New York to the west and the south .Connecticut is named for the Connecticut River, the major U.S. river that approximately...
, asserted that, on or about June 15, 1996, several correctional officers asked him to leave his cell, "placed him against a wall and struck him with their hands, kneed him in the back, [and] pulled his hair." Nussle alleged that the attack was unprovoked and unjustified, and that the officers told him they would kill him if he reported the beating.
Without filing a grievance through the Connecticut Department of Correction
Connecticut Department of Correction
The Connecticut Department of Correction is the agency responsible for corrections in the U.S. state of Connecticut. The agency operates 18 correctional institutions. It has its headquarters in Wethersfield.-History:...
, on June 10, 1999, Nussle commenced an action in federal district court under 42 U. S. C. §1983; he filed suit days before the three-year statute of limitations ran out on the §1983 claim. Nussle charged, principally, that the corrections officers' assault violated his right to be free from cruel and unusual punishment
Cruel and unusual punishment
Cruel and unusual punishment is a phrase describing criminal punishment which is considered unacceptable due to the suffering or humiliation it inflicts on the condemned person...
under the Eighth Amendment
Eighth Amendment to the United States Constitution
The Eighth Amendment to the United States Constitution is the part of the United States Bill of Rights which prohibits the federal government from imposing excessive bail, excessive fines or cruel and unusual punishments. The U.S. Supreme Court has ruled that this amendment's Cruel and Unusual...
, as made applicable to the States by the Fourteenth Amendment
Fourteenth Amendment to the United States Constitution
The Fourteenth Amendment to the United States Constitution was adopted on July 9, 1868, as one of the Reconstruction Amendments.Its Citizenship Clause provides a broad definition of citizenship that overruled the Dred Scott v...
. The District Court
United States District Court for the District of Connecticut
The United States District Court for the District of Connecticut is the Federal district court whose jurisdiction is the state of Connecticut. The court has offices in Bridgeport, Hartford and New Haven. Appeals from the court are heard by the United States Court of Appeals for the Second Circuit...
, relying on §1997e(a), dismissed Nussle's complaint for failure to exhaust administrative remedies.
Construing §1997e(a) narrowly because it is an exception "to the general rule of non-exhaustion in §1983 cases," the Court of Appeals for the Second Circuit
United States Court of Appeals for the Second Circuit
The United States Court of Appeals for the Second Circuit is one of the thirteen United States Courts of Appeals...
reversed the District Court's judgment; the appeals court held that "exhaustion of administrative remedies is not required for [prisoner] claims of assault or excessive force brought under §1983." Section 1997e(a) requires administrative exhaustion of inmates' claims "with respect to prison conditions," but contains no definition of the words "prison conditions." The appeals court found the term "scarcely free of ambiguity." In conflict with the Second Circuit, other Federal Courts of Appeals
United States courts of appeals
The United States courts of appeals are the intermediate appellate courts of the United States federal court system...
have determined that prisoners alleging assaults by prison guards must meet §1997e(a)'s exhaustion requirement before commencing a civil rights action.