Bressman v. Farrier

Background

These petitions involve state prisoners who sued in federal court under a civil-rights law, asking for damages or a declaration about the length or conditions of their confinement. The question presented is whether prisoners first must use state postconviction procedures under a statute for habeas cases before bringing these federal civil-rights suits. Different federal appeals courts have reached different answers: the Eighth Circuit said exhaustion is required; the Ninth Circuit required exhaustion when the damage claim depends on showing a sentence is invalid or too long; the Seventh Circuit took a contrary view. The petitions asked the Court to resolve this split.

Reasoning

The full Court declined to take up the dispute and denied review, so it did not decide the legal question on the merits. A dissenting Justice, joined by another Justice, explained that the issue has caused confusion across circuits and that the Courts of Appeals have noted tension between those decisions and past Supreme Court cases named Preiser and Wolff. The dissent argued the Court should have granted review to resolve the conflict, but the majority chose not to do so.

Real world impact

Because the Court denied review, the conflicting rules in the different federal circuits remain in effect. Prisoners seeking money or declaratory relief over sentence length or prison conditions will face different procedural hurdles depending on where their case is filed. The ruling is not a final decision on the legal question and could be revisited by the Court in a future case.

Dissents or concurrances

Justice White, joined by Justice O’Connor, dissented from the denial of review and would have granted the petitions because of the clear split among the Courts of Appeals and the apparent tension with prior Supreme Court decisions.