In Need of Correction: The "Iron Triangle" of the Prison Litigation Reform Act

For several decades, the federal docket has been crowded with prisoner challenges to conditions of confinement. To stem this perceived flood of frivolous litigation, Congress enacted the Prison Litigation Reform Act of 1996 (PLRA). Among other provisions, the PLRA mandates that prisoners exhaust intra-prison administrative remedies prior to bringing suit in federal court. While the exhaustion requirement has somewhat reduced the volume of prisoner litigation, it has also seriously curtailed prisoners' ability to secure redress of legitimate grievances. This Note argues that the PLRA is best understood as a flawed product of three competing imperatives: that penal facilities be administered without judicial or federal interference, that costs of incarceration be controlled, and that procedural conduits for the protection of prisoners' rights be instituted. This Note contends that a better balance can be struck between the three imperatives by rendering the administrative remedies regime more transparent in its operation.