U.S. Appeals Cowl: SHAKEDOWNS.

• Position: Brief Article

Harris v. Garner, 190 F.3d 1279 (11th Cir. 1999). Five inmates and six former inmates brought a civil rights action for damages and injunctive relief alleging violations of their constitutional rights during a prison "shakedown." The district court dismissed the case and the inmates appealed. The appeals court affirmed in part, vacated in part, and remanded. The appeals court affirmed application of the requirement of the Prison Litigation Reform Act (PLRA) that requires prisoners to exhaust all administrative remedies before bringing a federal action with respect to prison conditions, "even if it would be futile for [a] prisoner to seek such administrative remedies" and even if the administrative remedies are inadequate. But the appeals court held that the personal injury requirement of PLRA does not apply to former...