The U.S. Supreme Court case Woodford v. Ngo (2005) involved a prisoner, Viet Mike Ngo, who filed a lawsuit against prison officials for alleged violation of his constitutional rights without first exhausting all administrative remedies as required by the Prison Litigation Reform Act (PLRA). The court had to determine whether "proper exhaustion" meant that prisoners must complete the administrative review process in accordance with applicable procedural rules before filing suit in federal court. In a 6-3 decision, the Supreme Court ruled that proper exhaustion of administrative remedies is necessary under PLRA and it requires compliance with an agency's deadlines and other critical procedural rules. Therefore, Mr. Ngo’s claim was dismissed because he did not properly exhaust all available internal procedures before taking legal action.

In the dissenting opinion for Woodford v. Ngo, Justice Stevens argued that the majority's interpretation of the Prison Litigation Reform Act (PLRA) was too strict and did not align with Congress' intent when passing it. He contended that requiring prisoners to exhaust all administrative remedies before filing a lawsuit could lead to unnecessary delays in addressing serious constitutional violations. Furthermore, he pointed out that many prisons have complex and confusing grievance procedures which can be difficult for inmates to navigate without legal assistance. Thus, he believed this requirement could effectively deny some prisoners access to judicial review entirely. Additionally, Justice Stevens expressed concern about potential abuses of power by prison officials who might manipulate these procedures to prevent inmates from seeking redress in court.