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Brown v. Toombs, No. 97-1333 (6th Cir.) (139 F.3d 1102) (March 27, 1998) (Per Curiam)

Case held that district courts should enforce the PLRA's exhaustion requirements sua sponte.

Case noted mich of the philosophy behind the enactment of the PLRA when it commented: "Prior to the enactment of [this] statute, no significant incentives existed to deter the filing of state prison petitions raising insubstantial issues, ...

 

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