Does an Equitable Estoppel Exception Fly in the Face of the PLRA?
Unquestionably, the purpose of the PLRAs exhaustion requirement is to allow the administrative system to try to solve prisoners problems without the need for the prisoner to resort to federal courts to solve problems. If this end is achieved, it is undoubtedly a positive one. Administrative review prior to a suit conserves judicial resources, prevents control of prisons by judicial agencies, and likely prevents frivolous suits from reaching federal courts. With these purposes well-known, courts have continually construed Congresss intent liberally with respect to the exhaustion requirement, and they have not generally allowed exceptions to the exhaustion requirement. Even given these purposes and liberal construction of the exhaustion requirement, certain situations require that the exhaustion requirement be lifted in the interests of justice. It seems hard to believe that by implementing the exhaustion requirement, Congress meant to give prison officials free reign to prevent any chal
