Prisoner has exhausted administrative remedies when he complies with Bureau of Prisons rules
Richard Risher file a claim against the Director of the Bureau of Prisons and several individuals. His claim was dismissed after the trial judge concluded that he had not adequately complied with the rules governing administrative grievances. The Sixth Circuit reversed, holding that while Risher could have responded differently after he did not receive a timely response to his third-stage grievance, he was within the Bureau's rules by responding with a lawsuit. Established law required him to "make affirmative efforts to comply with the administrative procedures" and his complicance efforts need only be "sufficient under the circumstances."