University of Baltimore Law Review


This Comment will address the inadequacy and injustice of the PLRA, specifically the “proper exhaustion” rule as expressed in Woodford v. Ngo. “Proper exhaustion” means that “a prisoner must complete the administrative review process in accordance with applicable procedural rules, including deadlines, as a precondition to bringing suit in federal court.” Failure to adhere to even the slightest procedural requirement is sufficient to warrant procedural default, i.e., a dismissal regardless of the merits of the underlying claim. The PLRA seeks to achieve laudable ends, but the means by which it does so leave much to be desired.



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