Perttu v. Richards
View Official PDFBelow are plain-language sections to help you understand what the Court decided in Perttu v. Richards and why it matters. Quotes are taken from the syllabus (the Court’s short summary at the start of the opinion).
Summary
A short, plain-English overview of Perttu v. Richards.
The Supreme Court addressed whether the Seventh Amendment requires a jury trial on the issue of PLRA exhaustion when it is intertwined with the merits of a claim. The Court affirmed the Sixth Circuit's decision, holding that parties are entitled to a jury trial in such circumstances. This decision resolves a conflict with the Seventh Circuit's precedent.
Holding
The single most important “bottom line” of what the Court decided in Perttu v. Richards.
The Court held that parties are entitled to a jury trial on PLRA exhaustion when that issue is intertwined with the merits of a claim that requires a jury trial under the Seventh Amendment.
Constitutional Concepts
These are the Constitution-related themes that appear in Perttu v. Richards. Click a concept to see other cases that involve the same idea.
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Why Right to Jury Trial is relevant to Perttu v. Richards
The Court's decision hinges on whether the Seventh Amendment requires a jury trial when the exhaustion issue is intertwined with the merits of a claim.
Syllabus excerpt (verbatim)Held: Parties are entitled to a jury trial on PLRA exhaustion when that issue is intertwined with the merits of a claim that requires a jury trial under the Seventh Amendment.
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Why Procedural Due Process is relevant to Perttu v. Richards
The case involves procedural questions about how factual disputes related to exhaustion should be resolved, which implicates due process considerations.
Syllabus excerpt (verbatim)The question presented is whether a party has a right to a jury trial on PLRA exhaustion when that dispute is intertwined with the merits of the underlying suit.
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Why Substantive Due Process is relevant to Perttu v. Richards
The case involves the substantive right to have a jury trial on intertwined factual disputes, which relates to the protection of fundamental rights.
Syllabus excerpt (verbatim)The usual practice is that factual disputes regarding legal claims go to the jury, even if that means a judge must let a jury decide questions he could ordinarily resolve on his own.
Key Quotes
Short excerpts from the syllabus in Perttu v. Richards that support the summary and concepts above.
Parties are entitled to a jury trial on PLRA exhaustion when that issue is intertwined with the merits of a claim that requires a jury trial under the Seventh Amendment.
The PLRA is 'silent' on whether judges or juries should resolve exhaustion disputes, and that silence is 'strong evidence that the usual practice should be followed.'
The Sixth Circuit held that 'the Seventh Amendment requires a jury trial when the resolution of the exhaustion issue under the PLRA would also resolve a genuine dispute of material fact regarding the merits of the plaintiff's substantive case.'
