Opinion of the Court
§1997e(a). The District Court denied the motion. It noted factual disagreements between the parties about whether Younger had adhered to Maryland’s Administrative Remedy Procedure but concluded that it “need not resolve [those] disputes.” Younger v. Green, Civ. No. 16–3269 (D Md., Dec. 19, 2019), App. to Pet. for Cert. 42a. Instead, the court observed that there was “no dispute” that the Maryland prison system had internally investigated Younger’s assault. Ibid. And it held that this inquiry satisfied Younger’s exhaustion obligation.
The case then proceeded to a jury trial. Dupree did not present any evidence relating to his exhaustion defense, nor did he invoke exhaustion in his Rule 50(a) motion, which the District Court denied. The jury found Dupree and four of his codefendants liable and awarded Younger $700,000 in damages. Dupree did not file a post-trial motion under Rule 50(b).
Dupree appealed a single issue to the Fourth Circuit: the District Court’s rejection of his exhaustion defense at summary judgment. Unfortunately for Dupree, the appeal was over before it began. Fourth Circuit precedent maintains that a claim or defense rejected at summary judgment is not preserved for appellate review unless it was renewed in a post-trial motion—even when the issue is a purely legal one. Varghese v. Honeywell Int’l, Inc., 424 F. 3d 411, 422–423 (2005). Bound by this precedent, the panel dismissed the appeal.
The Fourth Circuit’s decision further cemented a conflict among the Courts of Appeals over whether a purely legal challenge resolved at summary judgment must be renewed in a post-trial motion in order to preserve that challenge for appellate review. We granted certiorari to resolve the disagreement.[1] 598 U. S. ___ (2023).
- ↑ Compare Rothstein v. Carriere, 373 F. 3d 275, 284 (CA2 2004) (post-trial motion not required to preserve claims of purely legal error); Frank
