The Fourth Circuit has rendered a decision on the impact of the PLRA on statutes of limitations. The experienced civil rights attorneys at Miller Law Group can help you navigate changing precedent in the area of prisoners’ rights.
The Prison Litigation Reform Act (PLRA) is a federal law that severely restricts prisoners’ ability to bring a lawsuit against the government for violations of their civil rights. One of the most notable restrictions is the PLRA’s exhaustion requirement, mandating that prisoners exhaust the internal grievance process before filing a civil rights lawsuit.
The exhaustion requirement had unintended consequences on statutes of limitations. In most § 1983 claims, plaintiffs must file their lawsuit within two or three years, or it is barred by the limitations period. As the grievance process is often time consuming, prisoners would frequently encounter limitations issues while attempting to comply with the PLRA.
Fortunately, the Fourth Circuit Court of Appeals remedied this issue by applying the doctrine of equitable tolling. In Battle v. Ledford, 912 F.3d 708 (4th Cir. 2019), the Court of Appeals held that the statute of limitations does not begin to run on a prisoner’s § 1983 claim until the grievance process is completed. The Court reasoned that, because exhaustion was mandatory, it would be inequitable to allow the statutory period to run—and possibly expire—as prisoners attempt to comply with the PLRA. This decision not only alleviated an unintended consequence of the PLRA, but it also provided future plaintiffs the clarity of a bright-line rule.
If you or a loved one suffered a civil rights violation while incarcerated, contact Miller Law Group today for a free consultation or call us at (919) 348-4361.
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