Juan Albino v. Lee Baca
Is it still good law? What later courts have actually done to this case.
Status
More on how this was screened
In Perttu v. Richards, the Supreme Court construed the Prison Litigation Reform Act to require a jury in that setting, displacing that part of Albino v. Baca. The Court reserved the constitutional question; its holding rests on statutory interpretation. Albino’s summary-judgment framework and allocation of exhaustion burdens are outside this treatment. The District of Oregon in Bartmess v. Beamer and the Northern District of California in Thompson v. Allison recognize the partial abrogation; the confirmed entry below is anchored on the Supreme Court opinion itself.
2,097 later cases cite Juan Albino v. Lee Baca; 400 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.
Relying on Juan Albino v. Lee Baca?
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Treatments
Abrogated
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The PLRA requires jury resolution of exhaustion facts intertwined with the merits of a jury-triable claim, displacing Albino’s procedure permitting a judge to decide those facts.
Perttu v. Richards · Supreme Court of the United States · filed
For those reasons, we hold as a matter of statutory interpretation that parties have a right to a jury trial on PLRA exhaustion when that issue is intertwined with the merits of a claim that falls under the Seventh Amendment. ... Two Circuits have suggested they agree with Perttu that factual findings related to exhaustion have no estoppel effect, but with little analysis and in cases that did not squarely present an estoppel issue. See Pavey, 544 F. 3d, at 742; Albino v. Baca, 747 F. 3d 1162, 1171 (CA9 2014). ... We therefore cannot reject the possibility that a judicial ruling on PLRA exhaustion might have estoppel effect in a later jury trial. And Beacon Theatres shows that the proper path in that situation is to hold the jury trial, not to change the estoppel rules.
Read the full opinion on CourtListener →
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