Skinner v. Wiley, 355 F.3d 1293 (11th Cir. 2004). · Go Syfert
Skinner v. Wiley, 355 F.3d 1293 (11th Cir. 2004). Cases Citing This Book View Copy Cite
94 citation events (94 in the last 25 years) across 14 distinct courts.
Strongest positive: Philip Houk v. R. D. Morris (flsd, 2025-12-17) · Strongest negative: Markovich v. Heuett (flsd, 2024-09-17)
Treatment trajectory · 2004 → 2026 · click a year to view as-of
2004 2015 2026
Top citers, strongest first. 50 distinct citers. How cited ↗
cited Abrogated Markovich v. Heuett
S.D. Fla. · 2024 · signal: see · confidence bake:cell
See Skinner v. Wiley, 355 F.3d 1293, 1295 (11th Cir. 2004) (per curiam), abrogated by Santiago-Lugo, 785 F.3d at 471 , 474–75, 474 n.5.
discussed Abrogated Lonnie Bernard Davis v. Warden, FCC Coleman - USP I
11th Cir. · 2016 · confidence bake:cell
Skinner v. Wiley, 355 F.3d 1293, 1295 (11th Cir. 2004) (per curiam), abrogated by Santiago-Lugo, 785 F.3d at 471, 474-75 , 474 n.5; see also Gonzalez v. United States, 959 F.2d 211, 212 (11th Cir. 1992) (per curiam), abrogated by Santiago-Lugo, 785 F.3d at 471, 474-75 .
discussed Cited as authority (verbatim quote) Philip Houk v. R. D. Morris
S.D. Fla. · 2025 · signal: see · quote attribution · 1 verbatim quote · confidence high
we hold that prisoners seeking habeas relief, including relief pursuant to 2241, are subject to administrative exhaustion requirements.
discussed Cited as authority (verbatim quote) Clifton Council, Jr. v. Warden Washington (2×) also: Cited as authority (rule)
M.D. Ala. · 2025 · signal: see · quote attribution · 1 verbatim quote · confidence high
we, like several other circuits, have held that the plra does not apply to habeas petitions . . . .
discussed Cited as authority (verbatim quote) George Tompkins v. Warden Washington (2×) also: Cited as authority (rule)
M.D. Ala. · 2025 · signal: see · quote attribution · 1 verbatim quote · confidence high
we, like several other circuits, have held that the plra does not apply to habeas petitions . . . .
discussed Cited as authority (verbatim quote) Wayne v. State of Florida
S.D. Fla. · 2023 · signal: see · quote attribution · 1 verbatim quote · confidence high
we hold that prisoners seeking habeas relief, including relief pursuant to 2241, are subject to administrative exhaustion requirements.
discussed Cited as authority (rule) Oluwatoyin Aborisade v. D. Taylor and Federal Prison Camp – Montgomery, Alabama
M.D. Ala. · 2026 · confidence medium
In the Eleventh Circuit, “prisoners seeking habeas relief, including relief pursuant to § 2241, are subject to administrative exhaustion requirements.” Skinner v. Wiley, 355 F.3d 1293, 1295 (11th Cir. 2004) (per curiam), abrogated on other grounds by, Santiago-Lugo v. Warden, 785 F.3d 467, 474-75 (11th Cir. 2015).
cited Cited as authority (rule) Andre Fragher v. Gwinnett County Department of Corrections
M.D. Ga. · 2025 · confidence medium
See 28 U.S.C. § 2254 (b); Skinner v. Wiley, 355 F.3d 1293, 1295 (11th Cir. 2004) (holding that exhaustion is required “in all habeas cases”).
discussed Cited as authority (rule) Oluwatoyin Aborisade v. Milton Washington
M.D. Ala. · 2025 · confidence medium
In the Eleventh Circuit, “prisoners seeking habeas relief, including relief pursuant to § 2241, are subject to administrative exhaustion requirements.” Skinner v. Wiley, 355 F.3d 1293, 1295 (11th Cir. 2004) (per curiam), abrogated on other grounds by, Santiago-Lugo v. Warden, 785 F.3d 467, 474– 75 (11th Cir. 2015).
cited Cited as authority (rule) James Deon Jones v. Lala D. Jones, et al.
M.D. Ga. · 2025 · confidence medium
See Dill v. Holt, 371 F.3d 1301, 1302 (11th Cir. 2004); Skinner v. Wiley, 355 F.3d 1293, 1295 (11th Cir. 2004) (holding that administrative exhaustion is required “in all habeas cases”).
discussed Cited as authority (rule) Luis Alberto Morales v. Warden Teketa Jester, et al.
M.D. Ga. · 2025 · confidence medium
See Dill v. Holt, 371 F.3d 1301, 1302 (11th Cir. 2004); Skinner v. Wiley, 355 F.3d 1293, 1295 (11th Cir. 2004) (holding that administrative exhaustion is required in all habeas cases), overruled in part on other grounds as recognized by Santiago-Lugo v. Warden, 785 F.3d 467, 472 (11th Cir. 2015).
discussed Cited as authority (rule) Rodney Terrance Cheese v. Denise Fachini, et al.
M.D. Ga. · 2025 · confidence medium
See Dill v. Holt, 371 F.3d 1301, 1302 (11th Cir. 2004); Skinner v. Wiley, 355 F.3d 1293, 1295 (11th Cir. 2004) (holding that administrative exhaustion is required in all habeas cases), overruled in part on other grounds as recognized by Santiago-Lugo v. Warden, 785 F.3d 467, 472 (11th Cir. 2015).
discussed Cited as authority (rule) Rashun Johnson v. Sheriff Matthew Moulton
M.D. Ga. · 2025 · confidence medium
See 28 U.S.C. § 2254 (b); Braden v. 30th Judicial Cir. Ct. of Ky., 410 U.S. 484, 489-92 (1973) (addressing issue raised in §2241 petition only after concluding the petitioner, a pretrial detainee, exhausted all available state court remedies for consideration of his constitutional claim); Skinner v. Wiley, 355 F.3d 1293, 1295 (11th Cir. 2004) (holding that administrative exhaustion is required “in all habeas cases,” including those brought under §2241).
discussed Cited as authority (rule) Marquez v. Washington (INMATE 1) (2×) also: Cited "see, e.g."
M.D. Ala. · 2025 · confidence medium
In Skinner v. Wiley, the Eleventh Circuit explained that it, like several other circuits, has held that the Prison Litigation Reform Act of 1995 (PLRA) does not apply to habeas petitions because (1) habeas petitions are not traditional civil actions; (2) Congress designed the PLRA to reduce frivolous civil actions from prisoners; and (3) the Antiterrorism and Effective Death Penalty Act (AEDPA), which affects habeas petitions . . . was enacted two days after the PLRA. 355 F.3d 1293, 1295 (11th Cir. 2004) (per curiam), abrogated on other grounds by, Santiago-Lugo v. Warden, 785 F.3d 467 , 474�…
discussed Cited as authority (rule) DANIEL v. STATE OF GEORGIA
M.D. Ga. · 2025 · confidence medium
See Braden v. 30th Judicial Cir. Ct. of Ky., 410 U.S. 484, 489-92 (1973) (addressing issue raised in § 2241 petition only after concluding the petitioner, a pretrial detainee, exhausted all available state court remedies for consideration of his constitutional claim); Skinner v. Wiley, 355 F.3d 1293, 1295 (11th Cir. 2004) (holding that 1 Although Daniel is not physically confined, he is “in custody” under § 2241.
discussed Cited as authority (rule) JACKSON v. SAMPSON
M.D. Ga. · 2025 · confidence medium
See 28 U.S.C. § 2254 (b)-(c); Skinner v. Wiley, 355 F.3d 1293, 1295 (11th Cir. 2004) (holding that administrative exhaustion is required “in all habeas cases”); Thomas, 371 F.3d at 787 (“A state prisoner cannot evade the procedural requirements of § 2254 by filing something purporting to be a § 2241 petition.”); Dill, 371 F.3d at 1303 (citing Medberry, 351 F.3d at 1059–62) (“Because [petitioner] is still in custody of officials of the state pursuant to the judgment of a state court, his § 2241 petition must comply with § 2254’s exhaustion requirement[.]”).
discussed Cited as authority (rule) LANDERS v. COUNTRYMAN
M.D. Ga. · 2025 · confidence medium
See 28 U.S.C. § 2254 (b); Braden v. 30th Judicial Cir. Ct. of Ky., 410 U.S. 484, 489-92 (1973) (addressing issue raised in § 2241 petition only after concluding the petitioner, a pretrial detainee, exhausted all available state court remedies for consideration of his constitutional claim); Skinner v. Wiley, 355 F.3d 1293, 1295 (11th Cir. 2004) (holding that administrative exhaustion is required “in all habeas cases,” including those brought under §2241), abrogated in part on other grounds as recognized by Santiago-Lugo v. Warden, 785 F.3d 467, 475 , 475 n.5 (11th Cir. 2015) (holding tha…
discussed Cited as authority (rule) Verduzco v. Martinez
W.D. La. · 2025 · confidence medium
Skinner v. Wiley, 355 F.3d 1293, 1295 (11th Cir. 2004), cert. denied, 124 S. Ct. 2112 (2004); Fuller v. Rich, 11 F.3d 61, 62 (5th Cir. 1994); see also Rourke v. Thompson, 11 F.3d 47, 49 (5th Cir. 1993).
discussed Cited as authority (rule) Carson v. Bennett
W.D. Wash. · 2024 · confidence medium
No. 45 at 2 (citing Skinner v. Wiley, 355 F.3d 1293, 1294 (11th 4 Cir. 2004); Carmona v. U.S. Bureau of Prisons, 243 F.3d 629, 634 (2.d Cir. 2001); 5 Walker v. O’Brien, 216 F.3d 626, 634, 639 (7th Cir. 2000)).
cited Cited as authority (rule) Razo-Elizarraras v. Warden, FCC Beaumont Medium
E.D. Tex. · 2024 · confidence medium
Skinner v. Wiley, 355 F.3d 1293, 1295 (11th Cir.), cert. denied, 541 U.S. 1036 (2004); Fuller v. Rich, 11 F.3d 61, 62 (5th Cir. 1994); see also Rourke v. Thompson, 11 F.3d 47, 49 (5th Cir. 1993).
discussed Cited as authority (rule) KNIGHT v. WALTON COUNTY JAIL
M.D. Ga. · 2023 · confidence medium
See 28 U.S.C. § 2254 (b); Thomas, 371 F.3d at 786 (explaining that “[a]mong the most fundamental common law requirements of § 2241 is that petitioners must first exhaust their state court remedies”); Skinner v. Wiley, 355 F.3d 1293, 1295 (11th Cir. 2004) (holding that administrative exhaustion is required “in all habeas cases,” including those brought under §2241); Braden v. 30th Judicial Cir. Ct. of Ky., 410 U.S. 484, 489-92 (1973) (addressing issue raised in §2241 petition only after concluding the petitioner, a pretrial detainee, exhausted all available state court remedies for …
cited Cited as authority (rule) MCDANIEL v. SUPERIOR COURT OF WALTON COUNTY GEORGIA
M.D. Ga. · 2023 · confidence medium
See Dill v. Holt, 371 F.3d 1301, 1302 (11th Cir. 2004); Skinner v. Wiley, 355 F.3d 1293, 1295 (11th Cir. 2004) (holding that administrative exhaustion is required “in all habeas cases”).
cited Cited as authority (rule) FLORENCE v. JACKSON
M.D. Ga. · 2023 · confidence medium
Skinner v. Wiley, 355 F.3d 1293, 1295 (11th Cir. 2004); Hughes v. Coursey, No. CV 110-077, 2010 U. S. Dist.
discussed Cited as authority (rule) Jackson v. USA
W.D. La. · 2022 · confidence medium
Skinner v. Wiley, 355 F.3d 1293, 1295 (11th Cir. 2004), cert. denied, 124 S. Ct. 2112 (2004); Fuller v. Rich, 11 F.3d 61, 62 (5th Cir. 1994); see also Rourke v. Thompson, 11 F.3d 47, 49 (5th Cir. 1993).
cited Cited as authority (rule) BERG v. TRICE
M.D. Ga. · 2022 · confidence medium
See Dill v. Holt, 371 F.3d 1301, 1302 (11th Cir. 2004); Skinner v. Wiley, 355 F.3d 1293, 1295 (11th Cir. 2004) (holding that administrative exhaustion is required “in all habeas cases”).
discussed Cited as authority (rule) Banks v. Warden
W.D. La. · 2022 · confidence medium
Skinner v. Wiley, 355 F.3d 1293, 1295 (11th Cir. 2004), cert. denied, 124 S. Ct. 2112 (2004); Fuller v. Rich, 11 F.3d 61, 62 (5th Cir. 1994); see also Rourke v. Thompson, 11 F.3d 47, 49 (5th Cir. 1993).
cited Cited as authority (rule) RUSSELL v. CALDWELL
M.D. Ga. · 2022 · confidence medium
See Dill v. Holt, 371 F.3d 1301, 1302 (11th Cir. 2004); Skinner v. Wiley, 355 F.3d 1293, 1295 (11th Cir. 2004) (holding that administrative exhaustion is required “in all habeas cases”).
discussed Cited as authority (rule) Banks v. Federal Bureau of Prisons
W.D. La. · 2022 · confidence medium
Skinner v. Wiley, 355 F.3d 1293, 1295 (11th Cir. 2004), cert. denied, 124 S. Ct. 2112 (2004); Fuller v. Rich, 11 F.3d 61, 62 (5th Cir. 1994); see also Rourke v. Thompson, 11 F.3d 47, 49 (5th Cir. 1993).
cited Cited as authority (rule) RUMPH v. JONES
M.D. Ga. · 2022 · confidence medium
See Dill v. Holt, 371 F.3d 1301, 1302 (11th Cir. 2004); Skinner v. Wiley, 355 F.3d 1293, 1295 (11th Cir. 2004) (holding that administrative exhaustion is required 2 “in all habeas cases”).
discussed Cited as authority (rule) Hoyle v. United States of America (INMATE 3)
N.D. Ala. · 2021 · confidence medium
Failure to file written objections to the Magistrate Judge’s findings and recommendations under the provisions of 28 U.S.C. § 636 (b)(1) shall bar a party from a de novo determination by the District Court of legal to § 2241, are subject to administrative exhaustion requirements.’” Santiago-Lugo v. Warden, 785 F.3d 467, 475 (11th Cir. 2015) (quoting Skinner v. Wiley, 355 F.3d 1293, 1295 (11th Cir. 2004)). 3 Since filing her petition, Hoyle has been transferred to the Alderson Federal Prison Camp in Alderson, West Virginia. 4 In filing her petition, Hoyle failed to pay the requisite fil…
discussed Cited as authority (rule) Hoyle v. United States of America (INMATE 3)
M.D. Ala. · 2021 · confidence medium
Failure to file written objections to the Magistrate Judge’s findings and recommendations under the provisions of 28 U.S.C. § 636 (b)(1) shall bar a party from a de novo determination by the District Court of legal to § 2241, are subject to administrative exhaustion requirements.’” Santiago-Lugo v. Warden, 785 F.3d 467, 475 (11th Cir. 2015) (quoting Skinner v. Wiley, 355 F.3d 1293, 1295 (11th Cir. 2004)). 3 Since filing her petition, Hoyle has been transferred to the Alderson Federal Prison Camp in Alderson, West Virginia. 4 In filing her petition, Hoyle failed to pay the requisite fil…
discussed Cited as authority (rule) Tuttle v. Ma'at
W.D. La. · 2021 · confidence medium
Skinner v. Wiley, 355 F.3d 1293, 1295 (11th Cir. 2004), cert. denied, 124 S. Ct. 2112 (2004); Fuller v. Rich, 11 F.3d 61, 62 (5th Cir. 1994); see also Rourke v. Thompson, 11 F.3d 47, 49 (5th Cir. 1993).
discussed Cited as authority (rule) Marshall Dewayne Williams v. FCC Coleman Warden
11th Cir. · 2021 · confidence medium
See Anderson, 111 F.3d at 806 ; Wilson v. Sargent, 313 F.3d 1315, 1318 (11th Cir. 1 This is because “(1) habeas petitions are not traditional civil actions; (2) Congress designed the PLRA to reduce frivolous civil actions from prisoners; and (3) the Antiterrorism and Effective Death Penalty Act (AEDPA), which affects habeas petitions and motions to vacate, was enacted two days after the PLRA.” Skinner v. Wiley, 355 F.3d 1293, 1294 (11th Cir. 2004) (per curiam), abrogated on other grounds as recognized by Davis v. Warden, FCC Coleman-USP I, 661 F. App’x 561, 562 (11th Cir. 2015) (per curi…
discussed Cited as authority (rule) Gates v. Crow (INMATE 2)
M.D. Ala. · 2020 · confidence medium
Regarding Respondent’s exhaustion argument, it is settled in this circuit that a federal prisoner who requests habeas corpus relief under 28 U.S.C. § 2241 must first exhaust his administrative remedies before seeking relief from this Court.3 See Skinner v. Wiley, 355 F.3d 1293, 1295 (11th Cir. 2004); Gonzalez v. United States, 959 F.2d 211 (11th Cir. 1992).
discussed Cited as authority (rule) Idada v. Spaulding
D. Mass. · 2020 · confidence medium
Ctr., 473 F.3d 229, 235 (6th Cir. 2006) (“[I]n contrast to the PLRA, § 2241’s exhaustion requirement is not statutorily required.”); Skinner v. Wiley, 355 F.3d 1293, 1294 (11th Cir. 2004) (per curiam); Monahan v. Winn, 276 F. Supp. 2d 196, 204 (D.
discussed Cited as authority (rule) Anderson v. F C I Oakdale
W.D. La. · 2019 · confidence medium
Skinner v. Wiley, 355 F.3d 1293, 1295 (11th Cir. 2004), cert. denied, 124 S. Ct. 2112 (2004); Fuller v. Rich, 11 F.3d 61, 62 (5th Cir. 1994); see also Rourke v. Thompson, 11 F.3d 47, 49 (5th Cir. 1993).
discussed Cited as authority (rule) Jones v. Bureau of Prisons
W.D. La. · 2019 · confidence medium
Skinner v. Wiley, 355 F.3d 1293, 1295 (11th Cir. 2004), cert. denied, 124 S. Ct. 2112 (2004); Fuller v. Rich, 11 F.3d 61, 62 (5th Cir. 1994); see also Rourke v. Thompson, 11 F.3d 47, 49 (5th Cir. 1993).
cited Cited as authority (rule) Scarffol v. Washington-Adduci
N.D. Ala. · 2019 · confidence medium
App’x 181, 183-84 (11th Cir. 2011) (citing Skinner v. Wiley, 355 F.3d 1293, 1294-95 (11th Cir. 2004)); see also, Santiago-Lugo vy.
discussed Cited as authority (rule) Variste v. Woods (INMATE 1)
M.D. Ala. · 2019 · confidence medium
Exhaustion It is well-settled that a federal prisoner who seeks habeas corpus relief under 28 U.S.C. § 2241 “must [first] exhaust his available administrative remedies before he can obtain relief [from the court on his petition].” Davis v. Warden, FCC Coleman-USP, 661 F. App’x 561, 562 (11th Cir. 2016), citing Santiago-Lugo v. Warden, 785 F.3d 467 , 474– 75 (11th Cir. 2015); Carmona v. United States Bureau of Prisons, 243 F.3d 629, 632, 634 (2nd Cir. 2001); Martinez v. Roberts, 804 F.2d 570, 571 (9th Cir. 1986); Fuller v. Rich, 11 F.3d 61, 62 (5th Cir. 1994). “[Federal] prisoners se…
discussed Cited as authority (rule) Yvon Themeus, Sr. v. Immigration and Customs Enforcement
11th Cir. · 2016 · confidence medium
Skinner v. Wiley, 355 F.3d 1293, 1294 (11th Cir.2004); Alanis-Bustamante v. Reno, 201 F.3d 1303, 1306 (11th Cir.2000) (dismissal of § 2241 petition for lack of subject-matter jurisdiction is reviewed de novo).
discussed Cited as authority (rule) Israel Santiago-Lugo v. Warden (2×) also: Cited "see"
11th Cir. · 2015 · confidence medium
Skinner, 355 F.3d at 1295 (“We agree with the reasoning of our sister circuits and hold that prisoners seeking habeas relief, including relief pursuant to §• 2241, are subject to administrative exhaustion requirements.”).
cited Cited as authority (rule) Wilson Gorrell v. Warden
11th Cir. · 2013 · confidence medium
Skinner v. Wiley, 355 F.3d 1293, 1294 (11th Cir.2004).
cited Cited as authority (rule) Austin v. Federal Bureau of Prisons, Designation & Sentencing Center
11th Cir. · 2013 · confidence medium
“We review de novo the district court’s denial of habeas relief under § 2241.” Skinner v. Wiley, 355 F.3d 1293, 1294 (11th Cir.2004).
cited Cited as authority (rule) Mark R. Louis v. Secretary, Florida Department of Corrections
11th Cir. · 2013 · confidence medium
Skinner v. Wiley, 355 F.3d 1293, 1294 (11th Cir.2004) (per curiam).
discussed Cited as authority (rule) United States v. Kenneth Bernard Nickson (2×) also: Cited "see"
11th Cir. · 2013 · confidence medium
Skinner v. Wiley, 355 F.3d 1293, 1295 (11th Cir.2004) (per curiam).
cited Cited as authority (rule) Gregory Alan Nichols v. Warden, FCC Coleman - Low
11th Cir. · 2012 · confidence medium
Id. “[P]risoners seeking habeas relief, including relief pursuant to § 2241, are subject to administrative exhaustion requirements.” Skinner v. Wiley, 355 F.3d 1293, 1295 (11th Cir.2004).
cited Cited as authority (rule) David A. Sawyers v. USP Atlanta Warden
11th Cir. · 2012 · confidence medium
Skinner v. Wiley, 355 F.3d 1293, 1294 (11th Cir.2004).
cited Cited as authority (rule) Watkins v. Haynes
11th Cir. · 2011 · confidence medium
Skinner v. Wiley, 355 F.3d 1293, 1294-95 (11th Cir.2004).
cited Cited as authority (rule) Danny Lee Wright v. Anthony Haynes, Warden
11th Cir. · 2011 · confidence medium
“We review de novo the district court’s denial of habeas relief under § 2241.” Skinner v. Wiley, 355 F.3d 1293, 1294 (11th Cir.2004).
cited Cited as authority (rule) Gary Steven Krist v. Ike Eichenlaub
11th Cir. · 2010 · confidence medium
Skinner v. Wiley, 355 F.3d 1293, 1295 (11th Cir.2004).
Retrieving the full opinion text from the archive…
Frank A. SKINNER, Petitioner-Appellant,
v.
Ron WILEY, Warden, Respondent-Appellee
19-10119.
Court of Appeals for the Eleventh Circuit.
Jan 8, 2004.
355 F.3d 1293
2004 U.S. App. LEXIS 229
Frank A. Skinner, Atlanta, GA, pro se., Robert David Powell, Atlanta, GA, for Respondent-Appellee.
Tjoflat, Dubina, Marcus.
Cited by 76 opinions  |  Published
PER CURIAM:

Appellant Frank A. Skinner filed the instant petition, pursuant to 28 U.S.C. § 2241, claiming that federal officials (1) planted narcotics in his prison locker; (2) illegally processed the incident report while he remained in segregation; and (3) pretended to give evidence to the Federal Bureau of Investigation to conduct an investigation. Skinner also alleged that his grievances were rejected and the staff tampered with his mail. The district court dismissed Skinner’s § 2241 petition for, among other things, failure to exhaust administrative remedies as required under § 1997e(a) of the Prison Litigation Reform Act (PLRA). On appeal, Skinner argues that the district court erred in determining that he had not exhausted his administrative remedies. Skinner also argues the merits of his petition.

We review de novo the district court’s denial of habeas relief under § 2241. Cook v. Wiley, 208 F.3d 1314, 1317 (11th Cir.2000).

After reviewing the record, we conclude that the district court did not err in determining that Skinner failed to exhaust his administrative remedies, although it did err in determining that the PLRA applied to Skinner’s habeas petition. We, like several other circuits, have held that the PLRA does not apply to habeas petitions because (1) habeas petitions are not traditional civil actions; (2) Congress designed the PLRA to reduce frivolous civil actions from prisoners; and (3) the Anti-terrorism and Effective Death Penalty Act (AEDPA), which affects habeas petitions and motions to vacate, was enacted two days after the PLRA. See Anderson v. Singletary, 111 F.3d 801, 803-05 (11th Cir. 1997) (holding that the PLRA’s filing fee provisions do not apply in §§ 2254 and 2255 petitions); see also Carmona v. United States Bureau of Prisons, 243 F.3d 629, 634 (2d Cir.2001) (stating that the PLRA does not apply to § 2241 petitions); Walker v. O’Brien, 216 F.3d 626, 633-34, 636-37 (7th Cir.2000) (holding that the PLRA does not apply to § 2241 and § 2254 petitions); Blair-Bey v. Quick, 151 F.3d 1036, 1040-42 (D.C.Cir.1998) (holding that the PLRA filing fee provisions do not apply to habeas petitions); Davis v. Fechtel, 150 F.3d 486, 490 (5th Cir.1998) (holding that the PLRA does not apply to § 2241 petitions); McIntosh v. United States Parole Comm’n, 115 F.3d 809, 812 (10th Cir.1997) (same).

[*1295] We have not conclusively determined whether, despite the PLRA’s inapplicability to habeas petitions, a prisoner is still required to exhaust his administrative remedies in all habeas cases. See Gonzalez v. United States, 959 F.2d 211, 212 (11th Cir.1992) (holding that prisoner who was denied parole was required to exhaust administrative remedies prior to filing § 2241 petition because “[ejxhaustion of administrative remedies is jurisdictional”); see also Irwin v. Hawk, 40 F.3d 347, 349 n. 2 (11th Cir.1994) (detailing the Bureau of Prisons’ administrative remedy procedures and requiring a prisoner to exhaust his claim administratively when seeking injunctive relief). Our sister circuits, however, have consistently held that prisoners must exhaust administrative remedies before habeas relief can be granted. Carmona, 243 F.3d at 630, 632, 634 (addressing § 2241 petition); Fuller v. Rich, 11 F.3d 61, 62 (5th Cir.1994) (addressing § 2241 petition); Little v. Hopkins, 638 F.2d 953, 953-54 (6th Cir.1981) (discussing habeas petitions in general); United States ex rel. Sanders v. Arnold, 535 F.2d 848, 850-51 (3rd Cir.1976) (same); Willis v. Ciccone, 506 F.2d 1011, 1014-15, n. 3 (8th Cir.1974) (same). We agree with the reasoning of our sister circuits and hold that prisoners seeking habeas relief, including relief pursuant to § 2241, are subject to administrative exhaustion requirements.

Upon review of the record and the parties’ briefs, we conclude that Skinner was required to exhaust his administrative remedies and failed to do so. Because his failure to exhaust administrative remedies resolves this appeal, we decline to discuss the merits of Skinner’s petition. Accordingly, we affirm the judgment of dismissal.

AFFIRMED.