Dexter Harmon v. Moses Jackson, Randy Watson, and Flora Washington

Summary

The court held that the federal Prison Litigation Reform Act exhaustion requirement does not apply to an action brought under the Arkansas Civil Rights Act against officials in their individual capacities or to Arkansas tort claims. Because the circuit court granted summary judgment solely on the ground that Harmon had not exhausted administrative remedies, the court reversed and remanded. Harmon's motion requesting a copy of the appellees' brief was moot.