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The doctrine of exhaustion of remedies prevents a litigant from seeking a remedy in a new court or jurisdiction until all claims or remedies have been exhausted (pursued as fully as possible) in the original one. The doctrine was originally created by case law based on the principles of comity.
Williams v. Reed, 604 U.S. ____ (2025), is a decision of the United States Supreme Court holding that state laws requiring exhaustion of state administrative remedies are preempted by 42 U.S.C. § 1983 of the federal Ku Klux Klan Act when they prevent a state court from hearing claims challenging delays in the administrative process.
The act mandated exhaustion of federal and state administrative remedies before an inmate could file a civil rights action. The Sixth Circuit along with some other lower courts adopted several procedural rules designed to implement this exhaustion requirement and facilitate early judicial screening.
Administrative law; General principles; Administrative court; Delegated legislation; Exhaustion of remedies; Justiciability; Judicial interpretation; Ministerial act
Darby v. Cisneros, 509 U.S. 137 (1993), was a case in which the United States Supreme Court held that federal courts cannot require that a plaintiff exhaust his administrative remedies before seeking judicial review when exhaustion of remedies is not required by either administrative rules or statute.
Ross v. Blake, 578 U.S. ___ (2016), was a United States Supreme Court case in which the Court held that "special circumstances" cannot excuse an inmate's failure to exhaust administrative remedies before filing a lawsuit under the Prison Litigation Reform Act of 1995, [1] but clarified that inmates are required to exhaust only administrative remedies that are genuinely available. [2]
The issue of non-justiciability has been recognized in Buttes Gas and Oil Co. v Hammer, [11] where Lord Wilberforce stated that the principle "that the courts will not adjudicate upon the transactions of foreign sovereign states" is not a matter of discretion, but is "inherent in the nature of the judicial process".
Fry v. Napoleon Community Schools, 580 U.S. 154 (2017), is a United States Supreme Court case in which the Court held that the Handicapped Children's Protection Act of 1986 does not command exhaustion of state-level administrative remedies codified in the Individuals with Disabilities Education Act (IDEA) when the gravamen of the plaintiff's lawsuit is not related to the denial of free ...