PLRA and Post-Release Exhaustion

The central issue raised on appeal is whether a person no longer incarcerated must exhaust administrative remedies pursuant to the PLRA as a prerequisite to filing an action in the district court relating to the conditions of his incarceration. This issue is one of first impression in this circuit.
Talamantes v. Leyva (9th Cir. Aug. 6, 2009) (holding that PLRA only applies to prisoners who are actually in custody).