Michael Johnson v. Jason Dalke

Wood, Chief Judge.

One of Congress's expressed goals when it passed the Prison Litigation Reform Act ("PLRA") was to rein in the flood of prisoner litigation-all too often frivolous or vexatious, it thought-clogging the courts. See Margo Schlanger, Inmate Litigation , 116 HARV. L. REV. 1555, 1633-34 & nn. 269-70 (2003) (citing Porter v. Nussle , 534 U.S. 516 , 525, 122 S.Ct. 983 , 152 L.Ed.2d 12 (2002) ; and 141 CONG. REC. 514, 627 (daily ed. Sept. 29, 1995) (statement of Sen. Hatch)). Of the many tools the law introduced to serve that purpose, one of the most potent is the so-called "three…