Inmates Complaining About Placement Policy Must Pursue Admin Remedies Against BOP

Garza v. Davis, 2010 WL 537769 (2/17/10) (Published) - After dealing with the issue several times in unpublished decisions, the 10th issues a published decision. Inmates in Florence prison camp have been complaining that the prison is categorically denying their placement in community correction centers and residential reentry centers for more than six months. The 10th holds the inmates must exhaust administrative remedies first. That course of action is not futile because the BOP memos allow for greater than six month placements and the appeal procedure provides for challenging the camp's policy to higher authorities above the camp administrators.