In Williams v. Rajoli, the court (Sykes/Easterbrook/Brennan, with Sykes writing) affirmed summary judgment against a prisoner for failing to exhaust his administrative remedies, as required by the Prison Litigation Reform Act (PLRA). Williams had begun the administrative remedy process, lodging an informal complaint as required. But when he received no response, he went no further. The court held that this was a failure, because the prison’s grievance policy required a formal complaint to be filed even if there was no response.