Seventh Circuit Review


Inmates confined to correctional facilities have necessarily forfeited many of their civil rights. But what happens when the institution that houses them restricts one of their few remaining rights? The answer for many inmates was to sue in federal court alleging violations under 42 USC § 1983. In an attempt to limit the number of inmate suits heard by an already over-burdened federal judiciary, Congress enacted the Prisoner's Litigation Reform Act ("PLRA") in 1996. The PLRA requires that inmates exhaust the administrative remedies available to them as a prerequisite to filing suit in federal court. The effects of the PLRA exhaustion requirement was to immediately and drastically constrain the civil rights of inmates by limiting access to federal courts. This article analyzes the Seventh Circuit's attempt to protect the rights of inmates and balance the interests of correctional officials against the protections of the Constitution.

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