Case Citator › William Sim Spencer v. Michael J. Bouchard

William Sim Spencer v. Michael J. Bouchard

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

Overruled in part
Court
Sixth Circuit
Citation
449 F.3d 721
Decided
Confirmed treatments
1
Flagged citations read
101 of 101
Citing cases (total)
280
Treatment dates
2007

Status

Overruled in part
A reviewed court has overruled part of this case’s holding. William Sim Spencer v. Michael J. Bouchard was overruled in part by Jones v. Bock; the confirmed treatment is listed below. All 101 flagged citations have been read.
More on how this was screened

The Supreme Court rejected the Sixth Circuit's rule requiring prisoners to name every defendant in a grievance before suing, which Spencer had applied. The Sixth Circuit later described Spencer as abrogated on other grounds by Jones in Villegas v. Metropolitan Government of Nashville. Spencer's decision that a prisoner may proceed with exhausted claims despite other unexhausted claims remains consistent with Jones.

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.

280 later cases cite William Sim Spencer v. Michael J. Bouchard; 101 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 William Sim Spencer v. Michael J. Bouchard?

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Treatments

Overruled in part

  • The Supreme Court rejected the rule Spencer applied that a prisoner must name every eventual defendant in the grievance to exhaust a claim.

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

    The Sixth Circuit threw out the Williams and Walton suits because those prisoners had not identified in their initial grievances each defendant they later sued. ... As the MDOC’s procedures make no mention of naming particular officials, the Sixth Circuit’s rule imposing such a prerequisite to proper exhaustion is unwarranted.
    Read the full opinion on CourtListener →

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