Generally, the Prison Litigation Reform Act (“PLRA”) requires jail inmates to grieve their complaints about jail conditions internally before suing in federal court. In Ross v. Black, et al., 578 U.S. __ (June 6, 2016), the U.S. Supreme Court recently addressed whether an inmate can rely on his participation in an internal investigation rather than following inmate grievance procedures. The Court rejected this end-run around the PLRA requirements and held that inmates must follow the required grievance procedures before filing suit, even if they otherwise alerted jail officials to their complaints by participating in another investigation.