LAMONT BERNARD HEARD v. YARNICE STRANGE; JEFFREY OOSTERHOF; ADAM DOUGLAS; CHRISTIAN ALCORN - Articles

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LAMONT BERNARD HEARD v. YARNICE STRANGE; JEFFREY OOSTERHOF; ADAM DOUGLAS; CHRISTIAN ALCORN

Posted by: Azya Thornton on Jan 29, 2025

Court: 6th Circuit Court (Published Opinions)

Attorneys 1: ARGUED: James Y. Xi, CLEMENT & MURPHY, PLLC, Alexandria, Virginia, for Appellant.

Attorneys 2: ARGUED: Joshua S. Smith, OFFICE OF THE MICHIGAN ATTORNEY GENERAL, Lansing, Michigan, for Appellees.

Attorneys 3: ON BRIEF: James Y. Xi, CLEMENT & MURPHY, PLLC, Alexandria, Virginia, for Appellant.

Attorneys 4: ON BRIEF: Joshua S. Smith, OFFICE OF THE MICHIGAN ATTORNEY GENERAL, Lansing, Michigan, for Appellees.

Judge(s): GILMAN, McKEAGUE, and THAPAR, Circuit Judges

Court Appealed: United States District Court for the Eastern District of Michigan at Detroit

THAPAR, Circuit Judge. Prisoners often have complaints about prison life. When these complaints arise, prisoners can’t go straight to federal court. The Prison Litigation Reform Act (“PLRA”) requires prisoners to seek relief from state prison officials before filing a federal lawsuit. This is called an “exhaustion” requirement since prisoners must exhaust their administrative remedies before suing. “We are not insensitive to the challenges faced by the lower federal courts in managing their dockets and attempting to separate, when it comes to prisoner suits, not so much wheat from chaff as needles from haystacks.” Jones, 549 U.S. at 224. But policy concerns about the strength of the PLRA’s exhaustion requirement don’t justify displacing Michigan’s valid tolling rule and departing from the federal courts’ usual practice of borrowing state tolling rules. Finding an inconsistency here “cannot fairly be viewed as an interpretation of the PLRA.” Id. at 216. We reverse.

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