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Perttu v. Richards

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Supreme Court of the United States
Perttu v. Richards
Term: 2024
Important Dates
Argued: February 25, 2025
Decided: June 18, 2025
Outcome
affirmed
Vote
5-4
Majority
Chief Justice John Roberts • Sonia Sotomayor • Elena Kagan • Neil Gorsuch • Ketanji Brown Jackson
Dissenting
Amy Coney Barrett • Clarence Thomas • Samuel Alito • Brett Kavanaugh

Perttu v. Richards is a case that was decided by the Supreme Court of the United States on June 18, 2025, during the court's October 2024-2025 term. The case was argued before the Supreme Court of the United States on February 25, 2025.

In a 5-4 opinion, the court affirmed the judgment of the United States Court of Appeals for the Sixth Circuit, holding that parties are entitled to a jury trial on Prison Litigation Reform Act exhaustion when that issue is intertwined with the merits of a claim that requires a jury trial under the Seventh Amendment. Justice Chief Justice John Roberts delivered the opinion of the court.[1]

HIGHLIGHTS
  • The issue: The case concerned the legal remedies available to imprisoned individuals. Click here to learn more about the case's background.
  • The questions presented: "In cases subject to the Prison Litigation Reform Act, do prisoners have a right to a jury trial concerning their exhaustion of administrative remedies where disputed facts regarding exhaustion are intertwined with the underlying merits of their claim?"[2]
  • The outcome: In a 5-4 opinion, the court affirmed the judgment of the United States Court of Appeals for the Sixth Circuit.[1]


    • The case came on a writ of certiorari to the United States Court of Appeals for the Sixth Circuit. To review the lower court's opinion, click here.

    Background

    Case summary

    The following are the parties to this case:[3]

    • Petitioner: Thomas Perttu
      • Legal counsel: Ann Maurine Sherman (Michigan Department of Attorney General)
    • Respondent: Kyle Brandon Richards
      • Legal counsel: J. Scott Ballenger (Appellate Litigation Clinic)

    The following summary of the case was published by Oyez[4]

    “ Richards, an inmate at Michigan’s Baraga Correctional Facility, sued Resident Unit Manager Thomas Perttu for sexual harassment and retaliation. Richards alleged that Perttu destroyed multiple grievances he attempted to file regarding Perttu's sexual abuse. Additionally, Richards claimed Perttu threatened to kill him if he continued trying to file grievances and wrongfully placed him in administrative segregation.


    After Perttu moved for summary judgment arguing the inmates failed to exhaust administrative remedies, and Richards cross-moved raising constitutional claims, the district court denied both motions due to factual disputes. A magistrate judge held an evidentiary hearing and recommended finding that Perttu proved the inmates failed to exhaust remedies. The district court adopted this recommendation and dismissed the case.

    Richards appealed, and after requesting supplemental briefing on whether the Seventh Amendment requires a jury for exhaustion disputes intertwined with case merits, the U.S. Court of Appeals for the Sixth Circuit concluded that it does and reversed the judgment of the district court.[5]

    		”

    To learn more about this case, see the following:

    Timeline

    The following timeline details key events in this case:

    Questions presented

    The petitioner presented the following questions to the court:[2]

    Questions presented:
    “ In cases subject to the Prison Litigation Reform Act, do prisoners have a right to a jury trial concerning their exhaustion of administrative remedies where disputed facts regarding exhaustion are intertwined with the underlying merits of their claim?[5] ”

    Oral argument

    Audio

    Audio of oral argument:[7]



    Transcript

    Transcript of oral argument:[8]

    Outcome

    In a 5-4 opinion, the court affirmed the judgment of the United States Court of Appeals for the Sixth Circuit, holding that parties are entitled to a jury trial on Prison Litigation Reform Act exhaustion when that issue is intertwined with the merits of a claim that requires a jury trial under the Seventh Amendment. Justice Chief Justice John Roberts delivered the opinion of the court.[1]

    Opinion

    In the court's majority opinion, Justice Chief Justice John Roberts wrote:[1]

    “

    If Congress had expressly provided in the PLRA that exhaustion disputes must be resolved by judges, then we would have been required to consider today whether such a provision violates the Seventh Amendment. But it is a ‘cardinal principle’ that we not address such a constitutional question unless necessary. Tull v. United States, 481 U. S. 412, 417, n. 3 (1987). Meanwhile, as we have shown, the usual practice of the federal courts in cases of intertwinement is to send common issues to the jury. Because nothing in the PLRA suggests Congress intended to depart from that practice here, we hold that parties are entitled to a jury trial on PLRA exhaustion when that issue is intertwined with the merits of a claim protected by the Seventh Amendment.

    The judgment of the United States Court of Appeals for the Sixth Circuit is affirmed. [5]

    		”
    —Justice Chief Justice John Roberts

    Dissenting opinion

    Justice Amy Coney Barrett filed a dissenting opinion, joined by Justices Clarence Thomas, Samuel Alito, and Brett Kavanaugh.

    In her dissent, Justice Barrett wrote:[1]

    “

    The Prison Litigation Reform Act of 1995 (PLRA) requires prisoners suing under 42 U. S. C. §1983 to first exhaust the administrative remedies that are ‘available’ to them. §1997e(a). In the decision below, the Sixth Circuit held that even if prisoners are not ordinarily entitled to a jury trial to resolve this threshold question, the Seventh Amendment requires a jury when exhaustion is intertwined with the merits. I would reverse. The jury right conferred by the Seventh Amendment does not depend on the degree of factual overlap between a threshold issue and the merits of the plaintiff ’s claim.

    The Court takes a different path. Instead of resolving the constitutional question that the parties brought to us, the Court holds that the PLRA itself requires a jury trial whenever an issue is common to exhaustion and the merits. No matter, the Court says, that the PLRA is silent on the subject. No matter that this statutory argument was not briefed before us. And no matter that it was not passed on by the courts below.

    Having taken this detour, the Court ends up in the wrong place. Reading the PLRA’s silence to implicitly confer a right to a jury trial contravenes not only basic principles of statutory interpretation, but also several of this Court’s precedents. I respectfully dissent. [5]

    		”
    —Justice Amy Coney Barrett

    Text of the opinion

    Read the full opinion here.

    October term 2024-2025

    See also: Supreme Court cases, October term 2024-2025

    The Supreme Court began hearing cases for the term on October 7, 2024. The court's yearly term begins on the first Monday in October and lasts until the first Monday in October the following year. The court generally releases the majority of its decisions in mid-June.[9]


    See also

    External links

    Footnotes

    1. ↑ 1.0 1.1 1.2 1.3 1.4 1.5 U.S. Supreme Court, "Perttu v. Richards," June 17, 2025
    2. ↑ 2.0 2.1 Supreme Court of the United States, "23-1324 PERTTU V. RICHARDS QP", October 4, 2024
    3. ↑ Supreme Court of the United States, "No. 23-1324," accessed November 24, 2024
    4. ↑ Oyez, "Perttu v. Richards," accessed November 24, 2024
    5. ↑ 5.0 5.1 5.2 5.3 Note: This text is quoted verbatim from the original source. Any inconsistencies are attributable to the original source.
    6. ↑ United States Court of Appeals for the Sixth Circuit, Richards v. Perttu, decided March 19, 2024
    7. ↑ Supreme Court of the United States, "Oral Argument - Audio," argued February 25, 2025
    8. ↑ Supreme Court of the United States, "Oral Argument - Transcript," argued February 25, 2025
    9. ↑ SupremeCourt.gov, "The Supreme Court at Work: The Term and Caseload," accessed January 24, 2022
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