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.