Thursday, May 23, 2013

McCarthy v. Madigan case brief

McCarthy v. Madigan case brief
503 U.S. 140, 112 S. Ct. 1081, 117 L. Ed. 2d 291 (1992)

CASE SYNOPSIS: Petitioner inmate filed an action raising a Bivens claim against respondent federal prison officials for monetary relief only based upon claims that the federal prison officials violated his constitutional rights by being deliberately indifferent to his medical needs. The United States Court of Appeals for the Tenth Circuit ruled that the inmate failed to exhaust administrative remedies. The inmate then appealed.

FACTS: The inmate specifically requested in his complaint that he sought only monetary damages. Thus, the court held that given the type of claim raised and the particular characteristics of the federal prison officials' general grievance procedure, the inmate's individual interests outweighed countervailing institutional interests favoring exhaustion, because neither purpose of protection of the administrative agency's authority nor promoting judicial efficiency were served. The court reasoned that the grievance procedure was not enacted by Congress nor mandated by it, thus the broad delegation of authority to the federal prison officials under 18 U.S.C.S. §§ 4001(b) and 4042 were irrelevant. Further, § 7 of the Civil Rights of Institutionalized Persons Act, codified at 42 U.S.C.S. § 1997e was not directly applicable to the inmate's Bivens claim, because Congress had not required exhaustion in this context. Finally the grievance procedures, under 28 C.F.R. pt. 542 (1991) heavily burdened the inmate with deadlines that created a high risk of forfeiture of a claim for failure to comply, and the administrative remedy did not authorize an award of monetary damages.

CONCLUSION: The court reversed the judgment.

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