Case Citator › Steele v. Federal Bureau of Prisons

Steele v. Federal Bureau of Prisons

Is it still good law? What later courts have actually done to this case.

Overruled in part
Court
Tenth Circuit
Citation
355 F.3d 1204
Decided
Confirmed treatments
1
Flagged citations read
94 of 94
Citing cases (total)
242
Treatment dates
2007
Overruled in part
A reviewed court has overruled part of this case’s holding. Steele v. Federal Bureau of Prisons is overruled in part: all 94 flagged citations have been read, and the 1 confirmed treatment is listed below. Jones v. Bock displaced Steele's rule that a prisoner must plead and document PLRA exhaustion, holding instead that nonexhaustion is an affirmative defense.
More on how this was screened

The reviewed lower courts reported that controlling change rather than independently treating Steele; many then applied Jones while preserving Steele's distinct holding that exhaustion is nonjurisdictional. Other nearby adverse language concerned unrelated precedents, claims, rulings, or procedural history. Three opinions that CourtListener lists twice were read for both flagged phrases. A short Forest Guardians v. United States Forest Service order withdrew a prior panel opinion and substituted the separately reviewed opinion; neither adversely treated Steele.

Every treatment on this page is written from the citing opinion itself, with a verbatim quote, never copied from a commercial citator. A citation flagged by our screen but not shown here was read and found not to weaken this case.

242 later cases cite Steele v. Federal Bureau of Prisons; 94 of those citations sat close to treatment language and were flagged for reading, and all of them have been read. Citations that did not sit near treatment language were not flagged and were not read one by one, so a court that weakened this case without using any of that language would not appear here.

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Treatments

Overruled in Part

  • The Supreme Court displaced Steele's requirement that prisoners plead and demonstrate PLRA exhaustion, holding that nonexhaustion is an affirmative defense.

    Jones v. Bock · Supreme Court of the United States · filed

    Some courts have found that exhaustion is subsumed under the PLRA’s enumerated ground authorizing early dismissal for “fail[ure] to state a claim upon which relief may be granted.” 28 U. S. C. §§1915A(b)(1), 1915(e)(2)(B); 42 U. S. C. §1997e(c)(1). See Baxter, supra, at 489; Steele v. Federal Bureau of Prisons, 355 F. 3d 1204, 1210 (CA10 2003); Rivera v. Allin, 144 F. 3d 719, 731 (CA11 1998). The point is a bit of a red herring. A complaint is subject to dismissal for failure to state a claim if the allegations, taken as true, show the plaintiff is not entitled to relief. If the allegations, for example, show that relief is barred by the applicable statute of limitations, the complaint is subject to dismissal for failure to state a claim; that does not make the statute of limitations any less an affirmative defense, see Fed. Rule Civ. Proc. 8(c).
    Read the full opinion on CourtListener →

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