Citation. McCarthy v. Madigan, 503 U.S. 140, 112 S. Ct. 1081, 117 L. Ed. 2d 291, 1992 U.S. LEXIS 1524, 60 U.S.L.W. 4191, 92 Cal. Daily Op. Service 1863, 92 Daily Journal DAR 2913, 6 Fla. L. Weekly Fed. S 43 (U.S. Mar. 4, 1992)
Brief Fact Summary. John J. McCarthy (Petitioner) was a prisoner who filed a complaint against four prison employees, solely for money damages, in the District Court for the District of Kansas. The District Court dismissed the complaint on the ground that Petitioner had failed to exhaust prison administrative remedies.
Synopsis of Rule of Law. The general rule is that parties must exhaust administrative remedies before seeking relief from federal courts. However, administrative remedies need not be pursued if the litigant’s interests in immediate judicial review outweigh the government’s interests in the efficiency or administrative autonomy that the exhaustion doctrine is designed to further.
Issue. Was Petitioner required to exhaust the prison system’s administrative remedies prior to bringing suit in a federal court, solely for money damages?
Held. No. Reversed and remanded. Given the type of claim raised and the particular characteristics of the Bureau’s grievance procedures, Petitioner’s interests outweighed the countervailing institution’s interests favoring exhaustion. Petitioner did not have to exhaust his constitutional claim for money damages. Turning to congressional intent, Congress neither enacted nor mandated the general grievance procedure promulgated by the Bureau. Further, the grievance procedure did not include any monetary relief. Nor did the interests of the Bureau weigh heavily in favor of exhaustion in terms of the remedial scheme. Dissent. None. Concurrence. The concurrence agreed with the holding based solely on the fact that the general grievance procedures did not provide for the award of money damages.
Discussion. The Court employed a balancing test, and found an absence of supporting material in the regulations, the record, and the briefs that the general grievance procedure was crafted with any thought toward the principles of exhaustion of claims for money damages. Petitioner’s interests outweighed those of the Respondents in this case, and exhaustion was not required.