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Here’s a twist in the way the law works: when a prisoner sues under the rule that says you must try every step inside prison before going to court, who decides if those steps really happened — a judge or a jury? The Supreme Court says that when those questions get mixed up with the heart of the case, a jury must decide. That’s because the law on prisoner complaints doesn’t spell out who sorts that out, and normally any factual fight tied to the main claim goes to a jury. This ruling settles a fight where different appeals courts had different answers. Chief Justice Roberts wrote for the five-justice majority, joined by Justices Sotomayor, Kagan, Gorsuch, and Jackson. Justice Barrett, joined by three colleagues, disagreed and would have left those decisions to judges.

Summary of the Case

Kyle Richards, a Michigan state inmate, sued prison officer Thomas Perttu, alleging that Perttu had sexually harassed him and other inmates and then destroyed Richards's grievance forms when he tried to complain. Perttu moved for summary judgment, arguing that Richards failed to exhaust available administrative remedies as required by the Prison Litigation Reform Act (PLRA). The Magistrate Judge held an evidentiary hearing, found Richards's witnesses not credible, and recommended dismissal without prejudice for failure to exhaust. The District Court adopted that recommendation. On appeal, a three-judge Sixth Circuit panel reversed, holding that the Seventh Amendment guarantees a jury trial whenever resolution of a PLRA-exhaustion dispute is "intertwined" with a claim that itself entitles the plaintiff to a jury. That decision conflicted with other circuit court precedent. The Supreme Court granted review to resolve whether prisoners have a right to jury trial on PLRA exhaustion when that question overlaps with the merits of their claim.

Opinion of the Court

Chief Justice Roberts, writing for the 5–4 majority (joined by Justices Sotomayor, Kagan, Gorsuch, and Jackson), affirmed the Sixth Circuit. The Court first applied the constitutional-avoidance principle, asking whether the PLRA can be read to confer a jury trial right and thereby avoid resolving whether Congress could have required judge-only factfinding without violating the Seventh Amendment. The majority held that PLRA exhaustion is an affirmative defense subject to the "usual practice" under the Federal Rules of Civil Procedure, and that under that background practice, courts send factual disputes intertwined with the merits to a jury. The PLRA is "silent" on whether a judge or jury must decide exhaustion and contains no indication that Congress intended to change these common-law principles. Nor does the PLRA's purpose of conserving judicial resources overcome the weight of this usual practice. Historical precedents confirm that factual questions intertwined with the merits belong before a jury. Accordingly, the Court interpreted the PLRA to require a jury trial on exhaustion when it overlaps with a claim that carries a Seventh Amendment right.

Dissenting Opinions

Justice Barrett, joined by Justices Thomas, Alito, and Kavanaugh, dissented. She argued that the Court improperly reframed a purely constitutional question as a statutory one, creating out of thin air a rule that the PLRA "implicitly" confers a jury right. She maintained that neither the text nor the history of the PLRA supports such an inference, and that the majority misapplied precedents designed only to guide judicial sequencing of legal and equitable claims, not to expand the jury-trial right itself.

When Prison Grievances and Jury Rights Collide: The Supreme Court's PLRA Decision

The Prison Litigation Reform Act requires inmates to exhaust all available administrative remedies before filing lawsuits. But what happens when the very person an inmate is suing allegedly prevented them from filing grievances? This case addressed exactly that situation. The Court determined that when factual disputes about whether an inmate properly exhausted administrative remedies overlap with the merits of their underlying claim, those disputes must be decided by a jury rather than a judge.

This ruling is significant because it recognizes that in cases where the same facts are central to both whether an inmate followed proper grievance procedures and whether their rights were violated, those factual questions should be decided together by a jury. The Court interpreted the PLRA's silence on who decides exhaustion disputes as incorporating the traditional legal practice of having juries resolve factual issues when those issues are intertwined with claims that carry a constitutional right to jury trial.

By ruling this way, the Court avoided directly addressing whether Congress could have required judges to decide these factual disputes without violating the Seventh Amendment's guarantee of jury trials. Instead, the Court found that the PLRA itself, properly interpreted, preserves the jury's traditional role in resolving factual disputes central to the merits of a case.