U.S. appeals court: exhaustion PLRA--Prison Litigation Reform Act.

• Position: Access to Courts

Carroll v. Yates, 362 F.3d 984 (7th Cir. 2004). A state prisoner brought a [section] 1983 Eighth Amendment action against corrections officials. The district court dismissed the action on the grounds of failure to exhaust administrative remedies, as required by the Prison Litigation Reform Act. The inmate appealed. The appeals court reversed and remanded, finding that the prisoner did not fail to exhaust by failing to appear in...