“No Grievance, No Federal Claim” – Third Circuit Clarifies that Temporary Grievance Filing Restrictions Do Not Excuse PLRA Exhaustion
(Commentary on Rhonshawn Jackson v. Knapp, 24-3183, 3d Cir. July 9 2025)

1. Introduction

Rhonshawn Jackson, an inmate in the Pennsylvania Department of Corrections (DOC), sued four Rockview prison officials alleging retaliation, deprivation of property, unconstitutional conditions of confinement, denial of due process, and civil conspiracy. After the Middle District of Pennsylvania granted summary judgment to the officials, Jackson appealed. On July 9 2025 a Third Circuit panel affirmed, holding that Jackson’s failure to exhaust administrative remedies under the Prison Litigation Reform Act (PLRA) barred most of his constitutional claims, and that the remaining claims failed on their merits. The Court also rejected Jackson’s contention that a 90-day restriction limiting him to “one grievance every 15 working days” relieved him of the PLRA exhaustion obligation.

Although the opinion is designated “Not Precedential,” it nevertheless clarifies a recurring question in prisoner civil rights litigation: a temporary, prospective limitation on filing new grievances does not excuse an inmate from appealing already-denied grievances or from refiling a grievance once the limitation expires. The decision thereby reinforces a strict application of the PLRA exhaustion requirement in the Third Circuit.

2. Summary of the Judgment

• Administrative Exhaustion: Jackson appealed only one of 44 grievances; the remainder were procedurally defaulted under 42 U.S.C. § 1997e(a).
• Eighth Amendment Claims: Brief exposure to a cold cell and to COVID-19, without evidence of deliberate indifference, did not constitute cruel and unusual punishment.
• First Amendment Retaliation: Alleged confiscation of sneakers and legal papers did not satisfy the causation and adverse-action elements.
• Fourteenth Amendment Due Process: No liberty interest in advancing beyond Phase 2 classification; loss of property was remediable by the prison’s grievance system.
• § 1985 Conspiracy: Claim failed for lack of class-based, invidious discriminatory intent.
• Qualified Immunity: Even if constitutional violations had been made out, the rights were not clearly established as to these facts.
• Outcome: District Court’s grant of summary judgment affirmed in full.

3. Analysis

3.1 Precedents Cited and Their Influence

The panel relied on—and in some instances merely reiterated—the following authorities:

• Williams v. Beard, 482 F.3d 637 (3d Cir. 2007) & Spruill v. Gillis, 372 F.3d 218 (3d Cir. 2004)
  – Established that PLRA exhaustion is mandatory and that failure to comply results in procedural default.
• Chavarriaga v. N.J. Dep’t of Corr., 806 F.3d 210 (3d Cir. 2015)
  – Clarified that prisoners have no federally protected liberty interest in a particular housing classification absent atypical and significant hardship.
• Tillman v. Lebanon County Correctional Facility, 221 F.3d 410 (3d Cir. 2000)
  – Held that an adequate post-deprivation remedy (e.g., grievance procedure) satisfies due process for property losses.
• Griffin v. Breckenridge, 403 U.S. 88 (1971) and Farber v. City of Paterson, 440 F.3d 131 (3d Cir. 2006)
  – Provide the “class-based animus” requirement for actionable § 1985 conspiracies.
• Anderson v. Liberty Lobby, Inc., 477 U.S. 242 (1986)
  – Set the summary-judgment standard for existence of a genuine dispute of material fact.

These precedents collectively underscored that Jackson’s procedural missteps—and not merely the merits—dictated the result. The Court applied them strictly, demonstrating unwillingness to carve out exceptions for grievance restrictions or for a prolific filer’s alleged roadblocks.

3.2 Legal Reasoning of the Court

1. Step 1 – Identify Exhaustible Claims

   The panel segregated claims tied to grievances Jackson never appealed from those tied to grievances he claims the prison would not accept. All but one fell into the first category.

2. Step 2 – Apply PLRA Exhaustion

   Invoking Williams and Spruill, the Court held that because Jackson did not complete the three-step DOC grievance process (initial review ➝ facility-manager appeal ➝ Central Office appeal), the majority of his § 1983 claims were barred.

   “The record before us demonstrates that Jackson only appealed the denial of one of the 44 grievances he filed.” (Slip op. at 5)

3. Step 3 – Evaluate Excuses

   Jackson argued the 90-day “one-grievance-per-15-days” restriction and alleged interference with grievance forms prevented exhaustion. The Court rejected both excuses as unsupported by evidence and, importantly, because the restriction did not impede appeals of already-denied grievances.

4. Step 4 – Merits of Non-Defaulted Issues

   For the handful of issues arguably exhausted (COVID exposure, cold cell, lost documents), the Court measured them against Eighth Amendment and retaliation standards:

   • Brief cold cell and pandemic exposure lacked “deliberate indifference.”
   • Lost documents were confiscated under colorable contraband policy; post-deprivation remedies existed (Tillman).
5. Step 5 – Reject Conspiracy Allegations

   No race or class-based animus alleged; § 1985 inapplicable.

3.3 Impact on Future Litigation

Although labeled “not precedential,” Jackson v. Knapp carries practical influence:

• Clarifies Limits of Grievance Restrictions: Future plaintiffs cannot rely on grievance caps to bypass exhaustion; they must still appeal past denials and may re-file once limits lapse.
• Emphasizes Evidentiary Burden: Self-serving declarations, devoid of supporting documentation or time-stamps that normally accompany grievances, will rarely raise a triable issue.
• Reinforces Property-Loss Doctrine: When a prison offers a post-deprivation remedy, § 1983 due-process claims for lost property will fail unless the remedy is unavailable or inadequate.
• Delineates Scope of § 1985: Retaliation for filing grievances, unconnected to protected class status, falls outside § 1985’s ambit.
• Strategic Guidance to Practitioners: Counsel representing inmates must meticulously track grievance timelines and include documentary proof of exhaustion; otherwise, summary judgment is likely.

4. Complex Concepts Simplified

• PLRA Exhaustion (42 U.S.C. § 1997e(a)): Before prisoners may sue in federal court, they must fully use the prison’s grievance system—every step, on time.
• Qualified Immunity: Shields officials from monetary liability unless they violated a “clearly established” constitutional right that a reasonable official would have known.
• Deliberate Indifference: A high Eighth Amendment bar requiring that officials know of and disregard an excessive risk to inmate health or safety.
• Procedural Default: Loss of the right to litigate a claim in court because a mandatory preliminary step (such as grievances) was skipped.
• § 1985 Conspiracy: A civil-rights conspiracy claim that, unlike § 1983, requires proof of class-based discriminatory intent.

5. Conclusion

Jackson v. Knapp reiterates a blunt but crucial message to prisoner-litigants and their counsel: strict compliance with the PLRA grievance process is non-negotiable. Neither administrative inconvenience nor temporary grievance limitations will excuse failure to exhaust. The decision also tightens the evidentiary screws—unsupported allegations, especially when contradicted by institutional records, will not generate genuine disputes for trial. Finally, the ruling reinforces doctrinal boundaries: ordinary retaliation is not a § 1985 conspiracy, and loss of property is not a due-process violation where an adequate post-deprivation remedy exists.

Going forward, the Third Circuit’s reaffirmation of these principles will likely streamline district court dockets—prompting early dispositive motions whenever exhaustion is suspect—and guide institutional policy makers to craft grievance restrictions that withstand judicial scrutiny.