No preliminary jury trials in federal court

Inmates have to jump through hoops if they want to bring a federal lawsuit over their ill-treatment in jail. They have to file a grievance with jail authorities. Of course, if the jail authorities deny they even received the grievance, then the inmate has a problem.

The case is Messa v. Goord, decided on July 26, 2011. What often happens in these cases is that the jail authorities say they never got the grievance, and the inmate says otherwise. Without a grievance, there's no lawsuit. In this case, the inmate says he did not file the grievance because the guards threatened him if he did file one. Prison staff also refused him assistance on this, though they deny the allegation. Who resolves this dispute? Judge or jury? The Court of Appeals says the judge does.

Messa says the Seventh Amendment entitles him to a jury trial to resolve the administrative exhaustion requirement. Not so fast, the Court of Appeals (Parker, Chin and Korman [D.J.]), says. The Seventh Amendment does provide for jury trials in certain instances. But, "[m]atters of judicial administration often require district judges to decide factual disputes that are not bound up with the merits of the underlying dispute. In such case, the Seventh Amendment is not violated." While ultimate factual determinations are for the jury, "here, the factual disputes relating to exhaustion are not intertwined with the merits of Messa's underlying excessive force claim."

That's not the only reason why the Second Circuit rules against plaintiff. In passing the grievance requirement in the Prison Litigation Reform Act, Congress wanted to let prisons decide on these matters before they reach the courts, and to reduce the quantity and improve the quality of inmate lawsuits. "To require a jury trial before it is certain that an inmate is entitled to to be in federal court would seriously undercut these goals," the Second Circuit reasons. In other words, Congress was sick and tired of inmate lawsuits. To empanel a jury to see if the inmate is allowed to even walk in the door with his case would undercut Congressional intent.