Erik Jackson Williams v. Riverside County

I. DISCUSSION

The Prison Litigation Reform Act of 1995 (“PLRA”) amended 42 U.S.C. § 1997e to provide that “[n]o action shall be brought with respect to prison conditions under [42 U.S.C. § 1983], or any other Federal law, by a prisoner confined in any jail, prison, or other correctional facility until such administrative remedies as are available are exhausted.” 42 U.S.C. § 1997e(a). Exhaustion is mandatory and no longer left to the discretion of the district court. See Ross v. Blake, 578 U.S. 632, 638-39 (2016); Woodford v. Ngo, 548 U.S. 81, 84 (2006). Section 1073 of Title 15 of the California Code of Regulations provides county jail inmates with a right to appeal and have resolved grievances relating to their confinement. See 15 Cal. Code Regs. § 1073. Pursuant to Section 1073, Riverside County has established grievance procedures for inmates at SCF. An inmate must exhaust his administrative remedies for constitutional claims prior to asserting them in a civil rights complaint. 42 U.S.C. § 1997e(a); McKinney v. Carey, 311 F.3d 1198, 1199 (9th Cir. 2002). Moreover, an inmate cannot file a complaint prior to completing exhaustion and seek a stay of the action to…