When does a claim accrue under the Prison Litigation Reform Act's mandatory exhaustion requirement?

QUESTION PRESENTED When a federal statute prohibits a plaintiff from filing a lawsuit until after the plaintiff completes mandatory exhaustion of administrative remedies, this Court and five Circuits hold that the plaintiffs claim does not accrue—and the statute of limitations does not begin to run—until after mandatory exhaustion is completed. This is consistent with the standard rule that a claim does not accrue until “the plaintiff can file suit and obtain relief.” In this case, however, the Ninth Circuit held that the statute of limitations begins running immediately on a claim governed by the Prison Litigation Reform Act (“PLRA”), even though § 1997e(a) of the PLRA mandates that a plaintiff exhaust his administrative remedies prior to filing suit. Under the Ninth Circuit’s approach, if exhaustion takes longer than the limitations period, then the limitations period expires on the plaintiffs claims before the PLRA allows him to file them in the first place. The question presented is: Where a federal statute—such as 42 U.S.C. § 1997e(a)—mandates that a plaintiff exhaust administrative remedies prior to filing suit, does the plaintiffs claim accrue only upon completion of mandatory exhaustion (as five circuits hold), or does it accrue before the completion of mandatory exhaustion, such that the limitations period can expire while the plaintiff is still prohibited by statute from filing his claim in court (as the Ninth Circuit held)? i