Douglas Thomas v. Shawn Woolum, Richard Kepler Charlotte Starcher Billie Waddell, Sr.

OPINION

MOORE, Circuit Judge.

Congress’s passage of the Prison Litigation Reform Act (“PLRA”) was an attempt to curb rampant prison litigation in the federal courts, but its enactment did not erode the role of the federal courts as vindicators of federal rights. The PLRA explicitly requires an inmate seeking to challenge prison conditions in federal court to exhaust any available administrative remedies, but the statute’s text does not condition access to the federal courts on satisfying the procedures and timelines of prison administrators. Thus, this case turns not on whether exhaustion is required, the answer to which is well settled, but on what exhaustion requires. We answer that question in light of Congress’s purpose in passing the PLRA and Supreme Court precedent regarding the exhaustion doctrine’s oft-stated purpose: to give prison officials the first opportunity to address inmate complaints according to their rules and procedures without letting those timetables dictate the outcomes of § 1983 actions. Accordingly, we hold that so long as an inmate presents his or her grievance to prison officials and appeals through the available procedures, the inmate has exhausted his or her administrative remedies, and a prison’s decision not to address the grievance because it was untimely under prison rules shall not bar the federal suit. We also hold, however, that when a grievance does not give prison officials notice of the nature of the inmate’s complaint, the inmate has not met the PLRA’s requirements. We thus AFFIRM the judgment of the district court.

I. BACKGROUND

When inmate Douglas Thomas told a supervising officer at the North Central Correctional Institution (“NCCI”) that he felt stressed out and needed “to lay it down fora few days,” the officer instructed Corrections Officer Shawn Woolum to take Thomas down to the segregation unit. J.A. at 84 (Springer Incident Rep.). Woolum, with whom Thomas had exchanged angry words earlier that day, took the opportunity to retaliate. While walking Thomas down to segregation, Woolum instructed another inmate who was present to leave and began to pummel the handcuffed Thomas. Woolum struck Thomas from behind, slammed him into a steel door, and banged his face against the steel door and cement walls. Upon their arrival at the holding cell, Woolum slammed Thomas into a steel door frame, picked him up, and slammed his face and head again into a cement wall. Woolum then stomped on Thomas’s foot. Thomas was in handcuffs during the relevant time and did not resist. As a result of Woolum’s actions, Thomas suffered a broken clavicle, broken ribs, a broken foot, facial lacerations, and massive swelling. Thomas alleges that Officers Richard Kepler, Charlotte Starcher, and Billie Waddell, Sr. observed the beating, but they failed to intervene. That was on November 5, 1997.

Various investigations followed. Officers Woolum, Kepler, and Waddell, along with the supervising officer who had suggested Thomas go to segregation and the nurse who treated Thomas’s injuries, filed “incident reports,” as prison regulations require when an employee struggles with an inmate or observes such a struggle. Ohio Admin. Code § 5120-9-02(A)(B) (1997). Thomas also filed a voluntary statement the day after the incident, in which he described what had happened and noted, “At some point when I was being beaten while wearing handcuffs I seen officers looking but the only on[e] I knew was Bill[ie] Waddell.” J.A. at 153.

In accord with regulations, prison officials then formed a Use of Force Committee to investigate the incident. Having heard additional statements, including another statement from Thomas describing Woolum’s actions, the Use of Force Committee issued a report concluding that Woolum had used an inappropriate amount of force; after disciplinary proceedings some time later, Woolum was fired. Under the administrative code, however, the inmate has no right to view the report or the evidence used to create it.

In addition to the prison’s internal administrative inquiry, Thomas invoked the formal grievance procedure. After being transferred to the Allen Correctional Institution (“ACI”), on May 1, 1998, Thomas requested a grievance form in order to report the November 5 incident. On or about May 4, 1998, Thomas filed a Notification of Grievance with NCCI’s institutional inspector. The Notification of Grievance form requires the prisoner to state “[t]he nature of the Grievance” in specific terms. Thomas stated, in part, as follows:

[O]n Nov. 5th while I was at NOCI I was assaulted by [Corrections Officer] Woolum while I was in handcuffs and I -had several bones broken and have since been transferred to A.C.I. administratively. Also as you know the state troopers & the FBI have conducted investigations- The Prisonf ] Litigation Reform Act & Title 42 of the United States Code require[ ] that a prisoner must exhaust state remedies prior to litigation. Therefore I ask that[Corrections Officer] Woolum be removed and released from his employment with the Department of Corrections and that I am awarded 5 million dollars.

J.A. at 33. The institutional inspector denied relief, apparently because the grievance was not filed within the thirty-day period required by Department of Rehabilitation and Correction(“Department”) policy-

Thomas pursued his grievance. Following the initial denial, Thomas appealed to the Chief Inspector. Thomas argued that the ACI law library had been provided copies of Department policy manuals only in the last thirty to forty-five days, that the thirty-day time limit was a recent change in policy, and that prisoners had not been notified of the change in policy. On October 30,1998, the Chief Inspector denied Thomas relief, determining that the grievance was filed too late and that information regarding the Department’s new time-limit policy was available in the law library. Accordingly, the decision of the Chief Inspector stated, “This Office will take no further action in regard to your complaint at this time.” J.A. at 35.

Thomas filed a complaint in state court on November 5, 1998, against Woolum and John Does and Jane Does, alleging that Woolum applied excessive force and that the John Does and Jane Does failed to protect Thomas and prevent the beating. Thomas claims that during discovery for the state-court action, he learned that Kepler, Starcher, and Waddell were present during the beating and failed to protect him. Indeed, statements that officers had filed with their incident reports and the Use of Force investigation — statements that Thomas had no right to access — indicated that other officers might have observed Woolum’s actions and not intervened. Thomas learned through these documents, for example, that Officer Kepler “heard a loud noise coming from the sally port” and “exited the R.I.B. office to investigate,” J.A. at 88; that Officer Wad-dell “walked into the hall[when] Thomas was being put in a holding cell,” J.A. at 89, which meant that, according to the Use of Force Committee’s conclusions, Waddell might have watched Thomas being pushed in a way that caused his head to strike the wall; and that Officer Starcher admitted having seen Thomas in the holding cell. From these newly available statements, Thomas appears to have concluded that these three officers may have witnessed Woolum’s assault.

The state court action against Woolum and the John Does and Jane Does was then dismissed without prejudice on October 20, 1999, and Thomas filed the original complaint in U.S. District Court on October 22, 1999. This time, Thomas sued not John Does and Jane Does, but armed with the information obtained in state court discovery, instead sued Woolum, Kepler, Starcher, and Waddell. After briefing,, the district court ruled that Thomas had not exhausted his remedies with respect to Kepler, Starcher, and Waddell. Thomas’s grievance form, the District reasoned, was “against defendant Woolum,” not the other defendants, J.A. at 114, so although the court eventually awarded Thomas $70,000 on his claim against Woolum, it dismissed his claims against Kepler, Starcher, and Waddell for failure to exhaust.

Thomas appealed the dismissal of his claims against the other defendants. The defendants now offer two ways in which Thomas failed to exhaust his remedies against Kepler, Starcher, and Wad-dell: (1) that we may not look at Thomas’s state prison grievance at all, and (2) that his grievance was insufficient to exhaust his claims. First, the defendants argue that Thomas failed to exhaust his administrative remedies because he did not file his grievance regarding the November 5, 1997 beating until May of 1998, after the thirty-day period in which the Department will accept grievances had expired. Second, they argue that his grievance was not “against” them, but against Woolum alone, and that he could not bring a suit against them. We review de novo any legal determinations made in dismissing a complaint for lack of subject matter jurisdiction, including a determination that the plaintiff did not exhaust administrative remedies, and we review any factual findings for clear error. See Cathedral Rock of North College Hill, Inc. v. Shalala, 223 F.3d 354, 358 (6th Cir.2000). We begin with the defendants’ first argument, for before we may determine whether Thomas’s grievance was sufficient, it is necessary for us to determine whether we may look at his grievance at all.

II. COMPLIANCE WITH STATE PROCEDURAL REQUIREMENTS

The Prison Litigation Reform Act prohibits inmates from challenging prison conditions in federal courts until they have exhausted their available administrative remedies. 42 U.S.C. § 1997e(a). There is no doubt that under the PLRA, exhaustion by prisoners is mandatory. See Booth v. Churner, 532 U.S. 731, 739, 121 S.Ct. 1819, 149 L.Ed.2d 958 (2001); see also Page v. Torrey, 201 F.3d 1136,1139 (9th Cir.1999) (recognizing that exhaustion requirement applies only to those who are “currently detained,” not former prisoners, and noting agreement of the Second, Seventh, and Eighth Circuits). The exhaustion requirement ensures that state prison systems will have an opportunity to handle prison grievances internally before recourse to the federal courts becomes available. But exhaustion is not the same as procedural default, and in similar state administrative contexts, the Supreme Court has held that state timelines cannot foreclose access to the federal courts when a petitioner has exhausted his or her state administrative remedies by bringing a grievance to the state and pursuing that grievance through to the administrative agency’s final ruling. That is, the exhaustion requirement is a “termination” requirement, requiring a petitioner to pursue administrative remedies as far as they exist. So long a prisoner meets this requirement, a federal claim will not be barred by the plaintiffs failure to comply with a state prison’s internal procedural requirements.

A. Exhaustion and the PLRA

By requiring prisoners who challenge the conditions of their confinement to exhaust first their state administrative remedies, the PLRA grants state prison systems the initial opportunity to address their internal problems. Whereas parts of the PLRA aim to ease the burden that meritless prisoner lawsuits impose on state law-enforcement officials and the federal docket, see, e.g., 42 U.S.C. § 1997e(c)(1) (permitting court to dismiss sua sponte prisoner suits that are obviously frivolous); id. § 1997e(f) (authorizing pretrial hearings via telephone or video conference rather than in-person appearance of the prisoner); id. § 1997e(g)(1) (permitting defendant to waive the right to reply to prisoner actions), nothing suggests that a goal of the act, and specifically, of the exhaustion requirement, was to defeat valid constitutional claims. Rather, the exhaustion requirement simply recognizes that unless a prisoner first presents his or her grievance to the state prison system, what will often be the most efficient mechanism to remedy a violation of federal law will be lost. See Porter v. Nussle, 534 U.S. 516, 525, 122 S.Ct. 983, 152 L.Ed.2d 12 (2002) (“Congress afforded corrections officials time and opportunity to address complaints internally before allowing the initiation of a federal case.”). The exhaustion requirement is therefore a benefit accorded to state prisons, an opportunity to satisfy those inmate grievances the state wishes to handle internally. See Preiser v. Rodriguez, 411 U.S. 475, 492, 93 S.Ct. 1827, 36 L.Ed.2d 439 (1973) (“Since these internal problems of state prisons involve issues so peculiarly within state authority and expertise, the States have an important interest in not being bypassed in the correction of those problems.”). It is “an accommodation of our federal system designed to give the State an initial opportunity to pass upon and correct alleged violations of its prisoners’ federal rights.” Picard v. Connor, 404 U.S. 270, 275, 92 S.Ct. 509, 30 L.Ed.2d 438 (1971). It is not, however, designed to permit state administrative timelines to handcuff the federal courts in adjudicating cases involving important federal rights. Accordingly, the PLRA does not contain any language regarding the timeliness of grievance filings or the application of procedural default; if the state forgoes an opportunity to decide matters internally whether for internal time constraints or any other reason, the PLRA has nonetheless served its purpose, and the prisoner may proceed to federal court.

Because the purpose of the exhaustion requirement is to provide states the first opportunity to resolve problems themselves, an inmate who has not pursued available administrative remedies may not yet proceed in federal court. Thus, we have clearly held that an inmate does not exhaust available administrative remedies when the inmate entirely fails to invoke the prison’s grievance procedure, see Hartsfield v. Vidor, 199 F.3d 305, 308-09 (6th Cir.1999); Brown v. Toombs, 139 F.3d 1102, 1104 (6th Cir.), cert. denied, 525 U.S. 833, 119 S.Ct. 88, 142 L.Ed.2d 69(1998), or when the inmate filed such a grievance but “did not appeal the denial of that complaint to the highest possible administrative level,” Wright v. Morris, 111 F.3d 414, 417 n. 3 (6th Cir.), cert. denied, 522 U.S. 906, 118 S.Ct. 263, 139 L.Ed.2d 190 (1997); see also Freeman v. Francis, 196 F.3d 641, 645 (6th Cir.1999). However, we have not previously ruled in a published opinion¹ that an inmate fails to exhaust his or her available administrative remedies when the inmate invokes the prison’s grievance system initially and appeals the denial of that grievance, but is time barred by the prison’s administrative procedures.

Our precedent demonstrates only that, in keeping with the plain language of § 1997e(a), a prisoner does not exhaust his administrative remedies when he fails to commence the grievance process or to run the gamut of potential appeals. In Harts-field, we dismissed a prisoner’s § 1983 suit because the disappearance of the prisoner’s grievance form, the lack of any evidence demonstrating that a grievance was actually filed, and the failure of the prisoner to refile a grievance did not support the argument that the prisoner ever began the grievance process. 199 F.3d at 308-09; see also Jones v. Smith, 266 F.3d 399, 400 (6th Cir.2001) (affirming dismissal of § 1983 suit because plaintiff prisoner was not vigilant enough in obtaining a grievance form after his initial request for one was denied and because the prisoner never made “any other attempt to obtain a form or to file a grievance without a form”). In Freeman, the exhaustion requirement was not met because the prisoner jumped the gun, and despite making some attempts to follow the proper grievance procedures, filed a federal complaint before completing all of the stages of the internal grievance process. 196 F.3d at 645. In Wright v. Morris, one prisoner filed an initial grievance, but then failed to appeal the denial of this grievance through the entire process. 111 F.3d at 417 n. 3; see also Harper v. Jenkin, 179 F.3d 1311, 1312 (11th Cir.1999) (dismissing § 1983 claim because the inmate did not appeal the denial of the grievance, thus failing to give the state a full chance to hear the grievance). These cases thus address the situation in which the prisoner is attempting to “bypass the exhaustion requirement by declining to file administrative complaints and then claiming that administrative remedies are time-barred and thus not then available.” Wright, 111 F.3d at 417 n. 3.

Here, however, Thomas filed a grievance in the prison’s formal grievance process, and once that grievance was denied, Thomas appealed as far as he could. He had quite literally exhausted his ability to go any further within the internal prison system. There were no more avenues to travel within the state prison system. If Thomas had failed to file, the state prison system would never have had any opportunity to review the claim. However, by filing, Thomas gave the state an opportunity to hear the claim and, by appealing, Thomas gave the state the opportunity to reconsider its decision. Thomas received the benefit of the potential that the state would hear his grievance by waiving the procedural guidelines, which the state could have done if it wanted to avoid federal court. The state received the benefit of dealing with the case internally if it so desired. The defendants, however, argue that exhaustion also requires more, and specifically, that it requires compliance with state administrative deadlines. Yet such an outcome would extend our established precedent beyond its present boundaries.

B. Exhaustion and State Procedural Rules

In two similar statutory contexts requiring resort to state administrative procedures, the Supreme Court has specifically held that a plaintiffs failure to comply with state statutes of limitations cannot prevent the plaintiff from proceeding to federal court.² Both the Age Discrimination in Employment Act and Title VII of the Civil Rights Act of 1964 require plaintiffs to present their grievances in the relevant state system before the plaintiff may initiate a federal suit. See 29 U.S.C. § 638(b) (ADEA); 42 U.S.C. § 2000e-5(c) (Title VII). In Oscar Mayer & Co. v. Evans, 441 U.S. 750, 99 S.Ct. 2066, 60 L.Ed.2d 609 (1979), the Supreme Court held that an ADEA plaintiff who had presented his grievance to the governing state agency after the state’s statute of limitations had expired had nonetheless satisfied the ADEA’s requirements and could proceed with his federal suit. See Oscar Mayer, 441 U.S. at 753, 99 S.Ct. 2066(“[T]he griev-ant is not required by [§ 633(b)] to commence the state proceedings within time limits specified by state law.”). Similarly, in EEOC v. Commercial Office Products Co., 486 U.S. 107, 108 S.Ct. 1666, 100 L.Ed.2d 96 (1988), the Supreme Court held that a Title VII plaintiffs failure to comply with a state statute of limitations in presenting her grievance to the state agency was irrelevant in determining whether she could proceed to federal court. See id. at 123, 108 S.Ct. 1666(“[S]tate time limits for filing discrimination claims do not determine the applicable federal time limit.”).

For both of those frameworks, the Supreme Court relied on three primary arguments to conclude that failure to comply with state time limits could not prevent the plaintiff from coming to federal court. All three arguments are applicable in the present case. First, the Court found in both instances that the absence of any mention in the statutes’ text of any requirement of timeliness under state law indicated Congress’s intent that state time requirements could not bar the federal claims. In both cases, the Court insisted that such a requirement could be imposed only by explicit mention. See Oscar Mayer, 441 U.S. at 759, 99 S.Ct. 2066 (“In particular, there is no requirement [in the ADEA] that, in order to commence state proceedings and thereby preserve federal rights, the grievant must file with the State within whatever time limits are specified by state law.”); Commercial Office Prods., 486 U.S. at 124, 108 S.Ct. 1666(“Ti-tle VTI, like the ADEA, contains no express reference to timeliness under state law.”). Second, the Court emphasized that state statutes of limitations should not serve as a bar to federal court “ ‘in a statutory scheme in which laymen, unassisted by trained lawyers, initiate the process.’ ” Oscar Mayer, 441 U.S. at 761, 99 S.Ct. 2066(quoting Love v. Pullman Co., 404 U.S. 522, 527, 92 S.Ct. 616, 30 L.Ed.2d 679 (1972)); accord Commercial Office Prods., 486 U.S. at 124, 108 S.Ct. 1666. Third, the Court reasoned that state procedural rules should not be able to prevent a federal court from remedying a harm that Congress sought to prevent. The requirement that plaintiffs first initiate state proceedings gave states “a limited opportunity” to resolve discrimination complaints, and “[i]ndividuals should not be penalized if States decline, for whatever reason, to take advantage of these opportunities.” Oscar Mayer, 441 U.S. at 761, 99 S.Ct. 2066; see also Commercial Office Prods., 486 U.S. at 123-24, 108 S.Ct. 1666 (recognizing that the filing provisions of the ADEA and Title VII are nearly identical and that the same policy considerations apply in each).

The latter two arguments unquestionably apply with equal force in the context of the PLRA. First, the prison grievant is generally the epitome of the lay person, unassisted by a trained lawyer, seeking to invoke the legal process. Further, if states may not use administrative time limits to defeat an ADEA or a Title VII claim, they should not be able to defeat a claim under the Civil Rights Act of 1871, Congress’s preeminent declaration that state officials may not undermine federal law. “A major factor motivating the expansion of federal jurisdiction through [the predecessor to 42 U.S.C. § 1983] was the belief of the 1871 Congress that the state authorities had been unable or unwilling to protect the constitutional rights of individuals or to punish those who violated these rights.” Patsy v. Bd. of Regents of Florida, 457 U.S. 496, 505, 102 S.Ct. 2557, 73 L.Ed.2d 172 (1982) (refusing, absent explicit congressional instruction, to create an exhaustion requirement for § 1983 suits). If we were to create a rule that permitted states to defeat § 1983 suits with their administrative time limits, however, and thereby let “unable or unwilling” state authorities prevail over “the constitutional rights of individuals,” id., we would have undone what Congress wrought. These rationales, which the Supreme Court relied on to hold that compliance with state statutes of limitations is irrelevant to a plaintiffs ability to bring a federal claim, apply with equal or stronger force to claims under § 1983.³

Thus the only question is whether the language of § 1997e, which prevents prisoners from challenging prison conditions “until such administrative remedies as are available are exhausted,” 42 U.S.C. § 1997e(a), distinguishes the PLRA from the ADEA and Title VII in such a way as to permit state agencies to defeat federal claims. Title VII’s filing requirement, after which the ADEA’s was patterned, reads as follows:

In the case of an alleged unlawful employment practice occurring in a State, or political subdivision of a State, which has a State or local law prohibiting the unlawful employment practice alleged and establishing or authorizing a State or local authority to grant or seek relief from such practice or to institute criminal proceedings with respect thereto upon receiving notice thereof, no charge may be filed under subsection [ (b)] of this section by the person aggrieved before the expiration of sixty days after proceedings have been commenced under the State or local law, unless such proceedings have been earlier terminated, provided that such sixty-day period shall be extended to one hundred and twenty days during the first year after the effective date of such State or local law. If any requirement for the commencement of such proceedings is imposed by a State or local authority other than a requirement of the filing of a written and signed statement of the facts upon which the proceeding is based, the proceeding shall be deemed to have been commenced for the purposes of this subsection at the time such statement is sent by registered mail to the appropriate State or local authority.

42 U.S.C. § 2000e-5(c). To be sure, as the Oscar Mayer court indicated, a requirement that a would-be federal plaintiff exhaust state remedies is different from a requirement that the plaintiff commence state proceedings. See Oscar Mayer, 441 U.S. at 761, 99 S.Ct. 2066. Accordingly, as Congress requires that an inmate exhaust available administrative remedies,42 U.S.C. § 1997e(a), the question is what exhaustion requires.

In a number of cases, the Supreme Court has suggested that exhaustion is the antonym of commencement. Whereas commencement requires the plaintiff to begin, exhaustion requires the plaintiff to finish. In Oscar Mayer, for example, the distinction between the ADEA’s requirement and an exhaustion requirement focused not on any purported difference in the two requirements’ power to defeat federal claims, but on the simple fact that 29 U.S.C. § 633(b) “requires only that the grievant commence state proceedings.” Oscar Mayer, 441 U.S. at 759, 99 S.Ct. 2066 (emphasis in original). Exhaustion, then, provides the flip side of that coin, “requir[ing] the court to delay action until the administrative phase of the state proceedings is terminated.” Gibson v.Berryhill, 411 U.S. 564, 574, 93 S.Ct. 1689, 36 L.Ed.2d 488 (1973) (emphasis added). Unlike the commencement requirement, which is crafted to give state agencies an opportunity to resolve a problem while federal action proceeds on a parallel track, see Oscar Mayer, 441 U.S. at 757, 99 S.Ct. 2066 (recognizing that ADEA set up “concurrent rather than sequential state and federal administrative jurisdiction”), exhaustion is a termination requirement, designed to keep federal courts out as long as the state administrative machinery is working to resolve the problem. Even the dissenters in Patsy v. Board of Regents of Florida, who argued that § 1983 included a judicially created exhaustion requirement for all plaintiffs, agreed that an exhaustion “does not defeat federal-court jurisdiction, it merely defers it.” Patsy, 457 U.S. at 532, 102 S.Ct. 2557 (Powell, J., dissenting). Thus when Congress imposed an exhaustion requirement in the PLRA, but imposed no other restrictions, it imposed a termination requirement. See, e.g., United States v. Wells, 519 U.S. 482, 495, 117 S.Ct. 921, 137 L.Ed.2d 107 (1997)(“[W]e presume that Congress expects its statutes to be read in conformity with this Court’s precedents.”).

With the PLRA, Congress could have required more than an exhaustion requirement, but it chose not to. Congress could have, for example, required in § 1997e(a) that, “In exhausting available administrative remedies, the prisoner shall comply with the prison’s reasonable time limits for filing grievances. Untimely claims shall be deemed procedurally defaulted.” Had Congress done so, .the present case would be much easier. But Congress did not, and the Supreme Court has instructed that we are not to impose such requirements when Congress refuses. See Commercial Office Prods., 486 U.S. at 124, 108 S.Ct. 1666 (“Title VII, like the ADEA, contains no express reference to timeliness under state law.”); Patsy, 457 U.S. at 514, 102 S.Ct. 2557 (reasoning that legislatures, not courts, are to determine “what consequences should attach to the failure to comply with procedural requirements of administrative proceedings”); Oscar Mayer, 441 U.S. at 759, 99 S.Ct. 2066 (“In particular, there is no requirement that, in order to commence state proceedings and thereby preserve federal rights, the griev-ant must file with the State within whatever time limits are specified by state law.”).

To reach the contrary conclusion, we would have to impose a judicially created procedural default rule, going well beyond the exhaustion rule that Congress imposed with the PLRA and contravening the Supreme Court’s explicit instructions in the Oscar Mayer line of cases. This may be a tempting and common mistake, but it is a mistake nonetheless, as Coleman v. Thompson, 501 U.S. 722, 111 S.Ct. 2546, 115 L.Ed.2d 640 (1991), shows. In discussing a habeas petitioner who filed an untimely notice of appeal in state court, the Court in Coleman reasons, “A habeas petitioner who has defaulted his federal claims in state court meets the technical requirements for exhaustion; there are no state remedies any longer ‘available’ to him.” Id. at 732, 111 S.Ct. 2546. That is, by filing the notice of appeal, even though untimely, the petitioner had exhausted his state remedies. The petitioner failed not because he had failed to exhaust his remedies, but because he had procedurally defaulted them. See id. (“In the absence of the independent and adequate' state ground doctrine in federal habeas, habeas petitioners would be able to avoid the exhaustion by defaulting their federal claims in state court.”) (emphasis added). Procedural default is thus distinct from the exhaustion requirement, an additional requirement added on top of exhaustion.

Although there may be an “interplay” between the two' doctrines, O’Sullivan v. Boerckel, 526 U.S. 838, 848, 119 S.Ct. 1728, 144 L.Ed.2d 1 (1999), and they appear together when there is a procedural default “at trial, on appeal, or on state collateral attack,” Edwards v. Carpenter, 529 U.S. 446, 451, 120 S.Ct. 1587, 146 L.Ed.2d 518 (2000), the Supreme Court’s habeas decisions make clear that they are different doctrines that impose different requirements. The judiciary created the procedural default rule to ensure that courts did not issue advisory opinions when an independent and adequate state ground supported a state court’s judgment, and extended the rule into the habe-as context only because “a state prisoner is in custody pursuant to a judgment” that would be rendered ineffective by a federal court’s ruling. Coleman, 501 U.S. at 729-30, 111 S.Ct. 2546 (emphasis in original). This extension of the procedural default rule into the habeas context obviously cannot support its extension into exhaustion of prison administrative remedies, as we have never considered a state warden’s decision on a grievance to be the equal of a full state-court judgment. Indeed, the Supreme Court’s habeas decisions instruct that, whereas the procedural default doctrine requires a habeas petitioner to comply with reasonable state procedural rules, the exhaustion requirement requires that “state prisoners ... give the state courts one full opportunity to resolve any constitutional issues by invoking one compete round of the’s established appellate review process.” Boerckel, 526 U.S. at 845, 119 S.Ct. 1728. This is precisely our holding here.

Thus the only ground for barring a federal § 1983 suit due to an untimely prison grievance is that we would otherwise render prison grievance procedures irrelevant. If a prisoner knows that he or she may file a federal suit by filing an untimely grievance, the argument goes, prisoners will have an incentive to bypass the prison grievance process by waiting until its deadline has passed, filing an untimely grievance, and then proceeding to federal court. Indeed, the Seventh Circuit appears to have relied on this policy argument in holding that an untimely grievance will bar a § 1983 suit. See Pozo v. McCaughtry, 286 F.3d 1022, 1025 (7th Cir.), cert. denied, 537 U.S. 949, 123 S.Ct. 414, 154 L.Ed.2d 293 (2002). However, not only does this argument sweep aside the meaning of exhaustion, it is an argument that the Supreme Court specifically rejected in Oscar Mayer itself. There is “[n]o reason” why one would “wish to forgo an available state remedy,” the Court reasoned; “[p]rior resort to the state remedy would not impair the availability of the federal remedy, for the two are supplementary, not mutually exclusive.” Oscar Mayer, 441 U.S. at 764, 99 S.Ct. 2066. That is, permitting prisoners to file in federal court following an untimely grievance in noway creates an incentive to bypass state remedies, for potential litigants will still have every incentive to raise their grievance within the prison’s timelines, because it is in the prison process that inmates will, for most practical purposes, receive their swiftest and most effective remedies. Those who bypass it will generally do so to their own disadvantage. In fact, the policy argument works in favor of the conclusion we reach here: prison administrators, knowing that their refusal to entertain grievances filed after certain deadlines will not protect them from subsequent litigation, will more likely take advantage of the opportunity to resolve the grievance that the PLRA has granted them.⁴

Thus the PLRA’s exhaustion requirement distinguishes the PLRA from the interpretations of Title VII and the ADEA, but not in a manner meaningful for this ease. Exhaustion of state administrative remedies under the PLRA requires a plaintiff not only to bring his or her claim before the state, but to see it through to completion, appealing denials as permitted and participating in offered hearings. Exhaustion also requires a plaintiff to bring a grievance to the state before coming to federal court even when the state has made clear that it will not grant the relief requested. See Booth, 532 U.S. at 736, 121 S.Ct. 1819. But just as a state prison system’s decision not to grant certain kinds of relief does not strip the federal courts of their power to grant that relief under § 1983, so too its decision not to grant relief in particular cases — whether for timeliness or for any other state procedural requirement — -does not strip the federal courts of their power to do so. Thomas brought his grievance to the prison officials’ attention, they refused to hear it, and he appealed their decision through each available level. That prison officials did not wish to address his complaint, as they prefer only to address complaints brought before them within thirty days, is irrelevant for our purposes. Thomas gave the state officers an opportunity, which is all that is required. We may not penalize Thomas simply because the prison does not wish to hear grievances more than thirty days after the incident. See Oscar Mayer, 441 U.S. at 761, 99 S.Ct. 2066. We therefore hold that a prisoner who has presented his or her grievance through one complete round of the prison process has exhausted the available administrative remedies under 42 U.S.C. § 1997e(a), regardless of whether the prisoner complied with the grievance system’s procedural requirements.

III. EXHAUSTION OF CLAIMS

Although a grievance that is untimely under prison rules still gives state prison officials an opportunity to address an inmate’s complaints, a grievance that does not give officials notice of the nature of the inmate’s grievance does not afford the officials the opportunity the PLRA requires. Thomas argues that between his official grievance form and his cooperation with the prison’s Use of Force investigation, in which he specifically mentioned the presence of other officers who failed to protect him, he gave prison officials sufficient notice for them to address his concerns in the grievance process. True though that may be, our cases require more. Because Thomas made no reference to the issues involved in his failure-to-protect claim in his grievance, we must find that he failed to exhaust his administrative remedies with respect to the claims against Kepler, Starcher, and Waddell.

Thomas’s grievance form does not offer the kind of information that our precedent requires for exhausting his claims against Kepler, Starcher, and Waddell. Thomas’s grievance mentions neither the defendants themselves nor any facts suggesting that officers other than Woolum knew anything of the incident. Thomas was indisputably aware of the other officers’ presence at the time, as he mentioned them in the incident report he filed the day after the beating, so this case falls under the rule of Curry v. Scott, 249 F.3d 493 (6th Cir.2001), which requires that “a prisoner file a grievance against the person he ultimately seeks to sue,” id. at 505. Similarly, in Hartsfield v. Vidor, we ruled that a prisoner who named three officers in his grievance, and who could have but did not name two additional officers, had not exhausted his administrative remedies with respect to the two previously unnamed officers. Hartsfield, 199 F.3d at 308-09. He thus did not “administratively exhaust his ... claim as to each defendant associated with the claim.” Burton v. Jones, 321 F.3d 569, 574 (6th Cir.2003). Although an inmate need not identify each officer by name when the identities of the particular officers are unknown, Thomas here knew one on-looking officer’s identity and knew that others had watched the beating as well. Accordingly, his grievance form should have noted either the other officers’ names or the fact that other officers had seen the beating.

Thomas suggests that his deficient grievance notwithstanding, he satisfied the exhaustion requirement by participating fully in the prison’s internal investigation. Indeed, the day after the attack, Thomas told prison officials that Officer Waddell and other officers had witnessed Officer Woolum’s actions, a notification that — when combined with Thomas’s subsequent filing of an official grievance regarding the incident — would seem to accomplish many purposes of the PLRA’s exhaustion requirement. However, it is no longer sufficient for an inmate simply to give prison officials notice of the complaint by cooperating with other investigations, as was sufficient in such pre-PLRA “substantial compliance” cases as Wolff v. Moore, 199 F.3d 324, 329 (6th Cir.1999). In our post-PLRA cases we have emphasized that “the exhaustion requirement in § 1997e(a) is directed at exhausting the prisoner’s administrative remedies,” and that Use of Force or other investigations do not satisfy the PLRA’s dictates. Freeman, 196 F.3d at 644. In determining whether the inmate has exhausted his or her remedies, we thus look to the inmate’s grievance, not to other information compiled in other investigations. Although an inmate grievance might conceivably specifically incorporate or otherwise refer to information previously obtained, it must do so in a manner that points prison officials to the relevant materials. That is not what happened here.

Finally, Thomas suggests that our requirement that prison grievances be filed “against” potential defendants, Curry, 249 F.3d at 505, mistakes the prison grievance process as a type of civil action. Grievances are not filed “against” individual persons, Thomas argues, but are rather filed regarding certain problems; accordingly, a grievance should be understood to exhaust remedies so long as it alerts prison officials to a problem to be investigated, whether or not it identifies specific individuals. Sims v.Apfel, 530 U.S. 103, 120 S.Ct. 2080, 147 L.Ed.2d 80 (2000), supports Thomas’s position. In Sims, a Social Security case, the Supreme Court ruled that even when a party is required to exhaust administrative remedies, the plaintiff is not necessarily required to exhaust each specific issue that he or she intends to bring to federal court. See id. at 112, 120 S.Ct. 2080 (plurality); id. at 113, 120 S.Ct. 2080 (O’Connor, J., concurring). Rather, “the desirability of a court imposing a requirement of issue exhaustion depends on the degree to which the analogy to normal adversarial litigation applies in a particular administrative proceeding.” Id. at 109, 120 S.Ct. 2080(majority). Applying the reasoning of Sims to the problem-solving mechanism of an inmate grievance procedure, a court might well conclude that the process is “inquisitorial rather than adversarial,” id. at 111, 120 S.Ct. 2080 (plurality), and thus that a court should not impose an issue-exhaustion requirement on top of the PLRA’s general exhaustion. On that view, an inmate’s grievance informing prison officials that he had been beaten by an officer would be sufficient to notify the prison of claims arising out of that beating, including, perhaps, a claim that other officers had witnessed the event but failed to intervene. However, we are bound by our decision in Curry, which apparently found the Sims reasoning inapplicable in the prison context and which thus requires prisoners to file grievances “against” specific defendants. See Hinchman v. Moore, 312 F.3d 198, 203 (6th Cir.2002) (noting that one panel cannot overrule a prior panel’s published decision). Thomas is thus subject to Curry’s standards; as his grievance contained no information relevant to his claims against Kepler, Starch-er, and Waddell, we conclude that he has not exhausted his claims with respect to those defendants.

IV. CONCLUSION

Had Thomas’s grievance pointed prison officials to the alleged presence of other officers when Officer Woolum was beating him, it would have given the officials a sufficient opportunity to investigate the other officers’ actions. The prison may have declined that opportunity, as it prefers to address only those grievances filed within a particular time limit. But the prison would have been given the opportunity, which is all that § 1997e(a) requires, so we hold that the timeliness of an inmate’s grievance is irrelevant under the PLRA’s exhaustion requirement. Because Thomas’s grievance did not contain the necessary information, however, it did not give prison officials the requisite opportunity. We thus conclude that Thomas failed to exhaust his administrative remedies with respect to Officers Kepler, Starcher, and Waddell, and we AFFIRM the district court’s judgment.

1 . We have rendered two unpublished orders in which we held that the exhaustion requirement was not met because of a failure to meet a state’s procedural deadlines. However, these unpublished orders have no prece-dential value and do not bind this panel. Jacobs v. Wilkinson, 21 Fed.Appx. 273 (6th Cir.2001) (Unpub.Order); Qawi v. Stegall, No. 98-1402, 2000 WL 571919 (6th Cir. May 3, 2000) (Unpub.Order).

2 . Analogizing the prison grievance system to other state administrative processes is more apt than analogizing it to the process of habe-as relief. The Supreme Court has not placed any procedural default hurdles upon the con-gressionally mandated exhaustion requirements for Title VII and the ADEA, which are chiefly concerned with administrative grievances. Thus, simply because the Supreme Court has crafted a procedural default rule in the habeas corpus context to shore up potential end-runs around the exhaustion requirement does not justify extending procedural default outside of the sphere of criminal law. There are key distinctions between the administrative grievance process and the habeas process that warrant disparate applications of a procedural default requirement. The notions of comity that prevent federal courts from unduly interfering with the state criminal judicial process in the habeas context do not have precisely the same resonance and intensity when federal courts are analyzing the outcome of a non-criminal state administrative process and when § 1983 interposes the federal courts as a vindicator of federal rights.

3 . Another, subsidiary argument relied on in the ADEA context supports our conclusion. The Supreme Court reasoned in Oscar Mayer that, because another provision of the ADEA identified a statute of limitations for claims brought under that Act, the Court could not "attribute to Congress an intent through [29 U.S.C. § 633(b) ] to add to these explicit requirements by implication and to incorporate by reference into the ADEA the various state age-discrimination statutes of limitations.” Oscar Mayer, 441 U.S. at 762-63, 99 S.Ct. 2066. This structural argument applies with similar force in the § 1983 context. Because 42 U.S.C. § 1988(a) indicates that the statute of limitations for an action under § 1983 is to be that provided for by "the common law, as modified by the constitution and statutes of the State” of jurisdiction, 42 U.S.C. § 1988(a), which under Ohio law provides for two years, see Browning v. Pendleton, 869 F.2d 989, 992 (6th Cir.1989) (en banc), for us to borrow a different, thirty-day statute of limitations suggested by an administrative agency for its own internal grievance process would attribute to Congress an intent that appears nowhere in the PLRA and is inconsistent with the reasoning of Oscar Mayer. Congress nowhere suggested an intention "to incorporate by reference,” Oscar Mayer, 441 U.S. at 762-63, 99 S.Ct. 2066, state administrative deadlines.

That Congress has instructed us to borrow a state’s statute of limitations on personal injury actions in no way implies that we should borrow a state prison's administrative deadlines. The two deadlines serve very different purposes; whereas a state legislature’s incentives in setting its personal injury statute of limitations will be well balanced, a state prison’s incentives in setting a time limit on inmate grievances — especially if the limit would insulate prison officials from § 1983 suits — would likely lead to shorter and shorter limitations periods. Compare, e.g., Kentucky Corrections Policy 14.6(VI)(J) (requiring aggrieved inmate to file grievance within five days, and appeal within three days), with Collard v. Kentucky Bd. of Nursing, 896 F.2d 179, 182 (6th Cir.1990) (recognizing statute of limitations for § 1983 actions at one year for those in Kentucky's general population). Although state officials may have legitimate reasons for imposing deadlines on inmate grievances, there is no reason that a prison’s legitimate interest in, for example, conserving investigative resources must prohibit federal court jurisdiction.

4 . There is no doubt that deadlines are mutually beneficial for both prison administrators and prisoners. The dissenting opinion claims that we view "time limits as mere traps for the unwary, and utterly fail[ ] to acknowledge that procedural deadlines serve the legitimate interests of both sides to a dispute" and the dissent accuses us of ascribing "nefarious motives ... to prison administrators who seek to enforce ... deadlines.” Diss. Op. at 738 (emphasis deleted). Then, while mistakenly criticizing the majority for an assumption it does not make, the dissenting opinion makes the equally sweeping and erroneous presumption that absent a procedural default requirement, prisoners will have "carte blanche ... to ignore any and all administrative time limits" and will purposefully default their administrative remedies to seek a trip to federal court. Id. at 739.

However, the perception that the absence of procedural default guidelines in this area will result in prisoners purposefully not filing grievances within the deadlines in order to bypass the internal prison system is counterbalanced by the equally real concern that in the presence of procedural default standards, prison administrators will impose shorter and shorter deadlines measured in hours and days, because prisoners will then have no recourse to the federal courts if they miss even one deadline. Following the dictates of Congress and refraining from judicially imposing a procedural default mechanism where none was legislated best balances these concerns and maintains the mutually advantageous internal grievance system.

Both prisoners and prison administrators gain little from prisoners jumping right to federal court as opposed to utilizing the prison grievance system first, because internal resolution of disputes gives prisoners more of an opportunity for quick resolution of their problems. Judicial restraint, exercised by the majority by not grafting a procedural default requirement onto the PLRA, serves both prisoners and prisons here because it maintains the potential for federal recourse. As a result, prison officials will not make grievance deadlines unduly short, as they will establish time-lines that are lengthy enough to permit administrators to evaluate grievances internally so as to avoid a trip to the federal courthouse. Prisoners in turn will have more time to meet deadlines and prepare their grievances.