Ramirez v. Young, No. 15-3298 (7th Cir. 2018)Annotate this Case
Under the Prison Litigation Reform Act of 1995 (PLRA), “[n]o action shall be brought with respect to prison conditions under [42 U.S.C. 1983], … until such administrative remedies as are available are exhausted.” Ramirez, who is a Spanish speaker, sued administrators and officers of the Western Illinois Correctional Center under 42 U.S.C. 1983 for alleged constitutional wrongs. As a prisoner. he was subject to the PLRA’s exhaustion requirement. Western Illinois had administrative remedies available. Ramirez did not use those procedures in a timely fashion to complain about the issues raised in his federal action. Ramirez claimed that the existing grievance process was unavailable to him because they were described to him only in a language that prison officials knew he did not understand. The district court held an evidentiary hearing, then dismissed Ramirez’s complaint without prejudice. The Seventh Circuit reversed. Because no administrator or officer of Western Illinois ever informed Ramirez of its grievance process in a way that he might reasonably understand, that process was unavailable to him and he was excused from the PLRA’s exhaustion requirement.