Hemphill v. New York.

• Position: ACCESS TO COURT - Brief Article

U.S. District Court

EXHAUSTION

PLRA -- Prison Litigation Reform Act

Hemphill v. New York, 198 F.Supp.2d 546 (S.D.N.Y. 2002). An inmate brought a [section] 1983 action alleging that prison staff used excessive force against him. The district court dismissed the action, finding that the inmate had failed to satisfy the exhaustion requirement of the Prison Litigation Reform Act (PLRA). According to the court, a letter the inmate sent to a prison superintendent could not be deemed a "grievance" for PLRA purposes. The court noted that the state corrections...