Rodolph Lanaghan v. Darryl Koch

Summary

Prison Litigation Reform Act exhaustion; administrative remedies "available" only if prisoner can physically access them and is adequately informed of procedures. The Seventh Circuit vacated dismissal, holding that an inmate with severe muscle disease who was physically unable to draft or file a grievance within the 14-day period, and whose prison handbook omitted the good-cause extension, did not fail to exhaust available remedies. The court rejected reliance on affirmative misconduct and focused on whether the inmate was unable to exhaust through no fault of his own.

Holdings

1. The grievance procedure was not available to Lanaghan because he was physically unable to file within the 14-day period and the good cause exception was not communicated to him, so the district court erred in dismissing the case for failure to exhaust.

Questions Presented

1. Whether the district court erred in holding that Lanaghan failed to exhaust available administrative remedies under the PLRA.

Disposition

vacated