Whether a prison grievance procedure is an available administrative remedy when it automatically refers a grievance for an internal investigation and terminates without adjudicating the prisoner's complaint

QUESTIONS PRESENTED Under 42 U.S.C. § 1997e(a), an incarcerated person cannot bring a prison-conditions action without first exhausting “such administrative remedies as are available.” A prison grievance process can be an available remedy, but only if it offers “relief for the action complained of.” Ross v. Blake, 578 U.S. 632, 642 (2016) (quoting Booth v. Churner, 532 U.S. 731, 738 (2001)). In Georgia, prison officials lack discretion to rule on grievances alleging excessive force. Instead, those grievances are automatically closed and forwarded to an unit. The grievance is not adjudicated, and the complainant is not informed of the outcome of the investigation. The same internal investigation may be initiated outside of the grievance procedure, including by a family member’s complaint to certain prison officials. This case presents two discrete questions: 1. Whether, under 42 U.S.C. § 1997e(a), a prison grievance procedure is an available administrative remedy when it automatically refers a grievance for an internal investigation and terminates without adjudicating the prisoner’s complaint. 2. Whether 42 U.S.C. § 1997e(a) requires a prisoner to use a prison’s grievance procedure when a grievance can only result in an internal investigation that has already been initiated by other means in accordance with the prison’s own policies. i