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On April 3, 2014, in Albino v. Baca, the U.S. Court of Appeals for the Ninth Circuit held that when a prisoner plaintiff has not been informed of a prison administrative remedy, that remedy is effectively unavailable to the prisoner for the purposes of the exhaustion requirement of the Prison Litigation Reform Act (PLRA). This decision conflicts with what a majority of other circuits have established and widens the gap between those circuits on this issue. This Comment argues for the U.S. Supreme Court to resolve this circuit split in a future case and hold that to fail to give a prisoner notice of an administrative remedy is to make that remedy effectively unavailable.


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8 Sep 2022
321 kB



  • Subject
    • Administrative Law

    • Civil Procedure

    • Law Enforcement and Corrections

  • Journal title
    • Boston College Law Review

  • Volume
    • 56

  • Issue
    • 6

  • Pagination
    • E. Supp. 151

  • Date submitted

    8 September 2022