Reyes v. Smith, No. 13-17119 (9th Cir. 2016)
Annotate this CasePlaintiff, a California state inmate, filed suit under 42 U.S.C. 1983 against defendant and other prison officials, alleging that they had violated the Eighth Amendment through deliberate indifference to his medical needs. The district court granted defendants' motion to dismiss because plaintiff failed to name two physicians in his grievance. The court held that a prisoner exhausts “such administrative remedies as are available,” under the Prison Litigation Reform Act of 1995 (PLRA), 42 U.S.C. 1997e, despite failing to comply with a procedural rule if prison officials ignore the procedural problem and render a decision on the merits of the grievance at each available step of the administrative process. When prison officials opt not to enforce a procedural rule but instead decide an inmate’s grievance on the merits, the purposes of the PLRA exhaustion requirement have been fully served: prison officials have had a fair opportunity to correct any claimed deprivation and an administrative record supporting the prison’s decision has been developed. In this case, plaintiff's grievance plainly put prison officials on notice of the nature of the wrong alleged in his federal suit because prison officials had full notice of the alleged deprivation and ample opportunity to resolve it. Accordingly, the court reversed and remanded for further proceedings.
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