The Supreme Court of the United States, in a unanimous decision, held that some courts are too restrictive in barring inmate lawsuits alleging violations of civil rights. This ruling overturned procedural obstacles in the 6th U.S. Circuit Court of Appeals that dismissed complaints alleging mistreatment brought by three Michigan inmates.

The Prison Litigation Reform Act, passed in 1995, was an attempt by the U.S. Congress to stem the tide of federal lawsuits brought by inmates. This act required inmates to follow a lengthy administrative grievance process before being permitted to sue in court. In part, the opinion written by Chief Justice John Roberts held that under the reform act, the failure of an inmate to exhaust all prescribed administrative procedures did not necessarily invalidate the claim and require automatic dismissal of the entire lawsuit.