The Sixth Circuit Court of Appeals vacated its own affirmation of the dismissal of a prisoner’s civil rights complaint after the Supreme Court found that the circuit’s imposition of the prerequisite to properly exhaust administrative remedies before filing a complaint was “unwarranted.”

Before the court was the appeal of prisoner L.C. Cohen, arguing a Michigan Federal District Court erred in dismissing his civil rights complaint for failure to exhaust his administrative remedies prior to filing his complaint.

After the Sixth Circuit affirmed that dismissal, Cohen sought and was granted certiorari with the Supreme Court. On remand, the Sixth Circuit was required to consider Cohen’s appeal under Jones v. Bock, 127 S.Ct. 910 (2007).

In Jones, the court held that the Prison Litigation Reform Act does not require a prisoner to specifically plead or exhaust his complaint. Furthermore, it held “exhaustion is not per se inadequate simply because an individual later sued was not named in the grievance.”

Accordingly, the matter was remanded to the district court for further proceedings. See: Cohen v. Corrections Corporation of America, 588 F.3d 299, (Sixth Cir. 2008).

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