Jessie D. Boyett, Jr. v. Burl Cain, Mdoc Commissioner, Mdoc Director of Offender Services, Mdoc Classification…

Summary

The Mississippi Supreme Court held that venue for a prisoner’s civil action against the Department of Corrections is proper in the county where the defendant resides or where a substantial act occurred, and affirmed that a plaintiff must exhaust administrative remedies before filing suit. Accordingly, the Court reversed the lower courts’ venue analysis but affirmed the dismissal on the ground of non‑exhaustion. The decision was issued on a limited certiorari addressing venue.