Terri McGuire-Mollica, proceeding pro se, sued federal prison officials for their years-long failure to treat a painful uterine fibroid that caused severe bleeding and other complications. Although she did everything Bureau of Prisons (BOP) regulations required of her to pursue her claim, the district court wrongly dismissed her case under the Prison Litigation Reform Act’s exhaustion requirement. The MacArthur Justice Center is fighting to overturn the district court’s erroneous decision and ensure that Ms. McGuire-Mollica and others like her receive their day in court.
While incarcerated at the Federal Correctional Institution in Aliceville, Florida, Terri McGuire-Mollica was diagnosed with a uterine fibroid that caused her to suffer extreme pain, bleeding, and discomfort. For years, she sought treatment from prison officials, including surgery to remove the fibroid. Prison officials repeatedly denied adequate treatment, and as they sat by, the fibroid tripled in size, and Ms. McGuire-Mollica continued to suffer pain, bleeding, and other serious medical complications.
Before bringing suit in federal court, Ms. McGuire-Mollica submitted an administrative grievance against prison officials for their failure to provide adequate medical care. She timely completed each step of the Bureau of Prisons’s process, including submitting her final appeal to prison mailroom officials for delivery to the BOP General Counsel. After mailroom officials received the appeal and provided Ms. McGuire-Mollica with a certified mail tracking number, however, the form disappeared. BOP officials later claimed that Ms. McGuire-Mollica’s final appeal was never received by the General Counsel or logged into the BOP’s administrative database.
Ms. McGuire-Mollica—acting pro se, or without counsel—then filed a lawsuit against prison officials alleging that they violated the Eighth Amendment by being deliberately indifferent to her serious medical needs. Though the district court expressly found that Ms. McGuire-Mollica had, in fact, properly completed and mailed her final appeal to the General Counsel, it nevertheless dismissed her complaint under the PLRA’s exhaustion requirement. The district court reasoned that she had not exhausted her administrative remedies because the BOP did not possess a record of her final appeal and she filed her original complaint before the General Counsel’s time to respond to a docketed appeal, had they received one, would have expired.
The MacArthur Justice Center represents Ms. McGuire-Mollica on appeal to the U.S. Court of Appeals for the Eleventh Circuit. We took on this case to ensure that Ms. McGuire-Mollica and others like her are not improperly denied their day in court even after they have done everything they are required to do to seek administrative relief before bringing suit.