Reyes v. Smith

The Prison Litigation Reform Act prohibits prisoners from bringing actions regarding prison conditions, requires inmates to pursue to every available step of his or her prison grievance process, and to adhere to the “critical procedural rules” of the grievance process.

Prison physician, Dr. Wesley Hashimoto, examined David Reyes, a California state inmate, for Reyes’s degenerative spine condition. With the approval of Dr. Christopher Smith, the Chief Physician and Surgeon, and Dr. Scott Heatley, the Chief Medical Officer, Dr. Hashimoto prescribed and ordered Reyes a regimen of pain medication including morphine. Reyes subsequently filed a prison grievance on the grounds that although he was suffering “unbelievable pain” the nurse refused to prescribe him anything but aspirin. The grievance committee determined that narcotics were “not medically necessary” pursuant to Reyes’s complaint. Reyes appealed the committee’s decision thrice before bringing this 42 U.S.C. § action in the California district court. The district court dismissed Reyes’s claims on the grounds that because Reyes did not name Drs. Smith and Dr. Heatly in his grievance, contrary to a California rule requiring inmates to list and describe all staff members involved in the grievance and their respective involvement. On appeal, the Ninth Circuit determined, pursuant to the Prison Litigation Reform Act (PLRA), 42 U.S.C. § 1997e, whether an inmate really did exhausted his administrative remedies if his grievance is decided on the merits at all levels of administrative review, notwithstanding the failure to comply with a procedural rule. The PLRA prohibits prisoners from bringing actions regarding prison conditions. Moreover, Section 1997e of the PLRA requires inmates to pursue to every available step of his or her prison grievance process and to adhere to “critical procedural rules” of that process. Although Reyes failed to include the two physicians names, the case was decided based on the merits of the grievance. Therefore, the panel held that Reyes claim was exhausted. REVERSED and REMANDED.