William Sim Spencer v. Michael J. Bouchard
Is it still good law? What later courts have actually done to this case.
Status
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.
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?
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
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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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