The question
Whether a party has a right to a jury trial on Prison Litigation Reform Act exhaustion when that dispute is intertwined with the merits of an underlying claim that itself carries a Seventh Amendment jury trial right.
Perttu v. Richards
What the Court decided
The Court held that parties are entitled to a jury trial on PLRA exhaustion when that issue is intertwined with the merits of a claim that requires a jury trial under the Seventh Amendment. The PLRA is silent on whether judges or juries resolve exhaustion disputes, and that silence means the usual practice under the Federal Rules of Civil Procedure applies, which sends factual disputes tied to legal claims to the jury. The Court construed the PLRA to require a jury trial in Richards's case, so it did not decide whether Congress could have required otherwise.
How the justices split
5-4The Court's opinion
Roberts, joined by Sotomayor, Kagan, Gorsuch, Jackson
The PLRA is silent on whether judges or juries resolve exhaustion disputes, so the usual practice under the Federal Rules of Civil Procedure applies and sends factual disputes tied to legal claims to the jury. Congress legislates against a background of common-law adjudicatory principles absent a contrary statutory purpose, and no such purpose is evident in the PLRA. When PLRA exhaustion is intertwined with the merits of a claim carrying a Seventh Amendment jury trial right, that exhaustion question goes to the jury, and courts should structure their order of operations to preserve the jury trial right. Construing the statute this way avoids deciding whether Congress could have required otherwise.
Dissenting
Barrett, joined by Thomas, Alito, Kavanaugh
The dissent disagreed with the majority's construction of the PLRA and its conclusion that PLRA exhaustion must be decided by a jury when intertwined with a claim carrying a Seventh Amendment jury trial right.
How we know · 5 sourced claims
The PLRA requires prisoners to exhaust available grievance procedures before filing suit in federal court under 42 U.S.C. Section 1997e(a).
Source: syllabus, Held
Parties are entitled to a jury trial on PLRA exhaustion when that issue is intertwined with the merits of a claim that requires a jury trial under the Seventh Amendment.
Source: syllabus, Held
The PLRA is silent on whether judges or juries should resolve exhaustion disputes, which is strong evidence that the usual practice of sending factual disputes to the jury should be followed.
Source: syllabus, Held
The Court construed the PLRA to require a jury trial in Richards's case and did not address whether Congress could have required otherwise without violating the Seventh Amendment.
Source: syllabus, Held
Roberts delivered the opinion of the Court, joined by Sotomayor, Kagan, Gorsuch, and Jackson, and Barrett filed a dissenting opinion joined by Thomas, Alito, and Kavanaugh.
Source: syllabus, lineup