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Administrative Law Keyed to Schwartz
McCarthy v. Madigan
Citation:
503 U.S. 140 (1992)Facts
John McCarthy was incarcerated at the federal penitentiary in Leavenworth when he filed a pro se complaint against four prison employees alleging they violated his Eighth Amendment rights through deliberate indifference to his medical needs following a back operation and psychiatric problems. McCarthy explicitly sought only monetary damages in his complaint. The Bureau of Prisons’ administrative remedy procedure required inmates to first attempt informal resolution, then file a formal complaint within 15 days of the incident, followed by appeals to the Regional Director within 20 days and to the General Counsel within 30 days if dissatisfied. This grievance procedure did not provide for monetary relief. The District Court dismissed McCarthy’s complaint for failure to exhaust administrative remedies, and the Court of Appeals affirmed, reasoning that administrative review would aid in measuring liability and determining damages.
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