Case Citator › Thomas v. Woolum

Thomas v. Woolum

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

Overruled in part
Court
Sixth Circuit
Citation
337 F.3d 720
Decided
Confirmed treatments
1
Flagged citations read
51 of 51
Citing cases (total)
51
Treatment dates
2006
Overruled in part
A reviewed court has overruled part of this case’s holding. Thomas v. Woolum was overruled in part on untimely prison grievances. The Supreme Court held in Woodford v. Ngo that the Prison Litigation Reform Act requires compliance with the prison grievance process's procedural rules, including deadlines.
More on how this was screened

All 51 flagged citations have been read. Later opinions continue to use Thomas for the separate requirement to pursue available grievance appeals through completion; the confirmed treatment is listed below. One fully readable citing opinion, Blake v. Ross (2015), did not contain a citation to Thomas despite being flagged; it was reviewed and produced no treatment. References in the other citing opinions to Woodford's abrogation of Thomas are reports of the Supreme Court's ruling, so the entry below rests on Woodford itself.

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.

51 later cases cite Thomas v. Woolum; 51 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 Thomas v. Woolum?

This page shows what later courts did to it. Ask about your specific facts and see whether it still carries your argument, with citations you can check.

Treatments

Overruled in part

  • The Supreme Court rejected Thomas's rule that pursuing an untimely prison grievance through appeals satisfies the PLRA's exhaustion requirement.

    Woodford v. Ngo · Supreme Court of the United States · filed

    The Ninth Circuit’s decision, while consistent with the decision of a divided panel of the Sixth Circuit in Thomas v. Woolum, 337 F. 3d 720 (2003), conflicts with decisions of four other Courts of Appeals. ... We granted certiorari to address this conflict, 546 U. S. 1015 (2005), and we now reverse. ... With this background in mind, we are persuaded that the PLRA exhaustion requirement requires proper exhaustion.
    Read the full opinion on CourtListener →

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