The Prison Litigation Reform Act (PLRA) became law in 1996 and was designed to decrease the rate of prison litigation in federal courts. It was passed in response to a perceived increase in litigation brought by incarcerated people and coincided with a boom in prison populations resulting from the 1994 Crime Bill. Rather than address the real causes litigation—including overpopulation, abuse, and other dangerous living conditions—the PLRA makes it extremely difficult for incarcerated people to legally advocate for themselves, even when they have a strong claim of a civil rights violation.
Webster Williams III is an incarcerated man with a disability that requires frequent trips to the restroom. But prison staff charged him with a disciplinary infraction for doing just that. Mr. Williams then went through the administrative grievance process, and when that didn't work, he filed a lawsuit alleging violations of federal disability protections. Invoking the PLRA, the district court threw out the lawsuit because Mr. Williams did not first go through a second administrative complaint process. That process, however, was not mentioned in the prison manual and Mr. Williams was never told about it.
The ACLU of North Carolina, the ACLU National Prison Project, and the Lawyers' Committee for Civil Rights Under Law now represent Mr. Williams on appeal at the United States Court of Appeals for the Fourth Circuit. Mr. Williams contends that incarcerated people with disabilities should not be forced to go through a second, redundant, and lengthy administrative process just so they can have their day in court.
Unfortunately, a three-judge panel of the United States Court of Appeals for the Fourth Circuit ruled against Mr. Williams. The ruling imposes extreme burdens on incarcerated people who face disability discrimination and wish to sue in federal court. It requires incarcerated plaintiffs with disabilities to jump through potentially countless administrative hoops, even if they have no reason to know that those hoops exist in the first place. The decision is unprecedented, conflicts with decisions of the Supreme Court, and creates a split with other federal appeals courts.
On May 12, 2023, the ACLU National Prison Project, the ACLU of North Carolina, and the Washington Lawyers' Committee asked the full Fourth Circuit to review that decision.