Punched on Camera, Blocked from Court: How the Prison Grievance System Fails
On November 2, 2023, Officer Sandra Munagay punched a federal prisoner identified in court records as J.M. in the face at USP Atwater in California. The assault was captured on security camera. Munagay pleaded guilty in January 2026 to falsifying records about the incident and was sentenced to four months in prison. But the violence didn’t end there — J.M. alleges he was kicked, beaten, and sexually assaulted by multiple officers in a hallway without cameras. Medical records from the prison where he was transferred that night noted bleeding and tenderness in his rectum.
Despite having more evidence than most incarcerated people — video footage and medical records — J.M. has faced a nearly impossible battle to seek justice through the courts. An investigation published July 13 by NPR and The Marshall Project reveals why: a federal grievance system designed as a pathway for redress has become an insurmountable barrier to accountability.
The Prison Litigation Reform Act: A 30-Year-Old Barrier
The root of the problem lies in the Prison Litigation Reform Act (PLRA) of 1996, which requires incarcerated people to complete every level of the Bureau of Prisons’ internal grievance process before filing a federal lawsuit. Failure to follow every requirement — including strict 20-day deadlines — results in automatic case dismissal. Since the PLRA’s passage, the rate of civil rights cases filed from prison has dropped significantly.
“Having a system that stands in the way and says, ‘You know what, because you filed that grievance after three days instead of after two, you are out of luck and out of court’ — that is a shocking betrayal of justice,” said Margo Schlanger, a University of Michigan Law School professor who has studied prison litigation across the U.S.
A System That Grants Fewer Than 2% of Complaints
The investigation, based on a database of nearly 1 million federal prison grievance cases from 2000 to 2024 published by the Data Liberation Project, found that less than 2% of grievances filed in federal prison in 2023 were granted. The grant rate has fallen from just under 7% in 2000. Nearly half of all complaints in 2023 were rejected for procedural issues — not evaluated on their merits. Only a quarter were actually denied after review of content.
“The guards functionally have power over whether a prisoner can sue them for their own misconduct,” said Colin Prince, a civil rights attorney representing J.M. “The entire system is layer upon layer of bureaucratic insulation against accountability. It simply prevents prisoners from getting access to the courts.”
Retaliation as a Feature, Not a Bug
For many incarcerated people, the grievance process itself invites retaliation. Prisoners must obtain grievance forms from the same staff members they may need to report. As attorney John Boston, co-author of the “Prisoners’ Self-Help Litigation Manual,” put it: “You can’t just walk over to a box on the wall that says grievances and put it in the slot. You’ve got to hand it to the correctional officer. And that right there is a prescription for mischief.”
Multiple prisoners reported that filing grievances leads to solitary confinement, loss of visitation and phone privileges, property confiscation, physical abuse, and being labeled a “snitch.” At FCI Dublin in California — which closed in 2024 over widespread sexual abuse — former prisoner Aron Laureano said officers punished people for filing complaints by reading grievances aloud and retaliating with solitary confinement. “They made it literally impossible for anybody to say anything,” she said. “And that’s why they got away with it for so long.”
A Government Accountability Office report published in May 2026 found that most surveyed prisoners said they could experience retaliation from staff if they reported sexual abuse. Less than half said they would feel comfortable reporting to the warden or a corrections officer.
J.M.’s Ordeal: A Case Study in Systemic Failure
J.M.’s journey through the federal prison system illustrates how these barriers compound. Before the assault at Atwater, he had served time at USP Big Sandy in Kentucky, where six staff members were later convicted for civil rights violations related to beating prisoners who requested protective custody. When J.M. tried to report abuse there, he says he was chained to a chair for 12 to 18 hours at a time with no food, water, or bathroom access.
After the Atwater assault, J.M. tried to file a grievance but didn’t have enough postage. He fashioned a fishing line out of plastic wrappers to trade food for stamps. His grievance was rejected — the bureau did not consider his issue “sensitive” enough to bypass the institution-level filing requirement. When he tried to appeal, prison staff seized and destroyed his paperwork, according to his lawsuit.
“He had been assaulted, isolated, trapped, and could not tell anyone who would listen,” his complaint states. “By mid-January 2024 … JM was expressing ‘suicidality’ to the mental-health department because he could not ‘participate’ in the ‘Administrative Remedy Process.’”
What’s Next: Oversight Without Funding
In July 2024, the Federal Prison Oversight Act was signed into law, which would create an independent ombudsman to investigate complaints from prisoners and their families. But Congress has not yet appropriated funding for its implementation. Without resources, the oversight mechanism remains theoretical.
Meanwhile, the Bureau of Prisons maintains that its grievance system works. Spokesperson Randilee Giamusso said the program “is intended to solve problems and be responsive to issues raised by inmates, and does not prevent inmates from pursuing litigation.”
But for J.M., who continues to fight his case while being moved to yet another facility out of state, the reality is different. He’s currently trying to appeal a grievance about not receiving his allotment of postage stamps — but he doesn’t have enough stamps to mail the paperwork.
“I’m resilient. I’m not going to give up just because other people failed,” J.M. said. “I’m going to keep filing no matter how small or big the situation is, and hopefully something will change. These are the rules I gotta follow. This is the only way I got to fight.”
As Professor Schlanger noted, attempts to significantly reform the PLRA “have gone nowhere” in the three decades since its passage. The question remains whether the growing body of evidence — from video-recorded assaults to comprehensive data on grievance denials — will finally move lawmakers to act.