top of page


Amond publishes in Loyola Law Review

Kristen Amond recently published in article in the Loyola Law Review discussing the applicability of the Prison Litigation Reform Act’s administrative exhaustion requirement during the COVID-19 pandemic.

The article tells the story of Ronald Marshall, a man incarcerated at B.B. Rayburn Correctional Center in Angie, Louisiana. Kristen was appointed by the U.S. District Court for the Eastern District of Louisiana pro bono panel to represent Mr. Marshall in a Section 1983 civil rights lawsuit challenging the medical care he was receiving in prison. When the COVID-19 pandemic was raging worldwide, especially in prisons, Mr. Marshall sought immediate relief to require the prison to provide basic COVID-19 protections, such as soap, hand sanitizer, and masks.

Mr. Marshall’s claims were dismissed because the PLRA requires incarcerated people to exhaust administrative remedies before filing a lawsuit in federal court, which regularly takes months. The article argues that, in the context of the COVID-19 pandemic, prison grievance processes are not “available” because they do not fit the problem and instead act as “simple dead ends” because they cannot provide incarcerated people with timely relief.

The article is published in the Spring 2021 Issue of the Loyola Law Review at 67 Loy. L. Rev. 299 (2021).

bottom of page