Roundtree Goodman v. James Rubenstein, Commissioner, 16-1207

Petitioner Roundtree Goodman (pro se at filing) sought habeas relief on April 7, 2011, alleging inadequate mental-health care and seeking expungement of certain prison disciplinary actions; he stated the petition did not challenge his 1979 conviction.
Respondent (Commissioner of Corrections) moved to dismiss and requested screening under the West Virginia Prisoner Litigation Reform Act (WVPLRA) and Rules 12(b)(6)/56.
The circuit court dismissed the petition on November 28, 2016, finding (1) lack of jurisdiction due to failure to comply with presuit notice requirements (W. Va. Code § 55-17-3), (2) failure to exhaust administrative remedies under the WVPLRA, and (3) that some claims had already been addressed.
Goodman argued on appeal that habeas petitions are not subject to the presuit notice statute and that he had exhausted remedies by filing grievances at Mt. Olive and later at Northern Regional Jail.
The Supreme Court of Appeals reviewed de novo and affirmed dismissal solely on the ground that Goodman failed to exhaust administrative remedies at the facility where he was housed (Northern), rendering dismissal proper without resolving the presuit notice issue.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether habeas petition is subject to presuit notice under W. Va. Code § 55-17-3	Habeas petitions are exempt from presuit notice requirements	Circuit court relied on plaintiff’s noncompliance with presuit notice to dismiss	Court did not decide; affirmed on other grounds (exhaustion)
Whether Goodman exhausted administrative remedies under WVPLRA before filing	Exhaustion satisfied by grievances at Mt. Olive and by grievances filed at Northern after suit initiation	Plaintiff failed to exhaust remedies at Northern before suing; Mt. Olive grievances irrelevant	Held: Plaintiff failed to exhaust remedies at Northern; dismissal affirmed
Whether filing grievances after filing suit can cure exhaustion defect	Argued post-filing grievances and prior Mt. Olive grievances suffice	Post-filing grievances insufficient; must exhaust administrative remedies at current facility before suit	Held: Post-filing grievances do not cure lack of exhaustion here; prior Mt. Olive grievances do not suffice
Whether claims were already addressed such that suit could proceed	Plaintiff contested only mental-health claims on appeal; did not contest dismissal of expungement claims	Circuit court found some issues already addressed	Court affirmed without reaching substantive merits because exhaustion failure was dispositive

White v. Haines, 217 W.Va. 414, 618 S.E.2d 423 (W. Va. 2005) (WVPLRA requires exhaustion of administrative remedies at the correctional facility where the inmate is housed before filing civil action challenging conditions of confinement)
State ex rel. McGraw v. Scott Runyan Pontiac-Buick, Inc., 194 W.Va. 770, 461 S.E.2d 516 (W. Va. 1995) (standard of review for dismissal on motion: de novo)