--- title: "Fazzini v. Northeast Ohio Correctional Center" citation: "473 F.3d 229 (6th Cir. 2006)" authority_id: "AUTH-CA6-FAZZINI-473-F3D-229" authority_type: "case" jurisdiction: "federal_sixth_circuit" precedential_status: "binding_in_ca6" url: "https://jason93.com/legal/federal-process/authorities/AUTH-CA6-FAZZINI-473-F3D-229/" legal_review: "2026-08-25" links_checked: "2026-10-15" links_available: 1 links_checked_count: 1 license: "CC BY 4.0" --- # Fazzini v. Northeast Ohio Correctional Center ## Holdings used - Federal prisoners ordinarily must exhaust before § 2241 review, but the nonstatutory requirement allows bounded futility, unavailable-relief, and administrator-caused-failure exceptions. ## Material limitation Binding only in the Sixth Circuit and only for the bounded procedural postures in the linked claims. The original 2006 opinion was not located in the current official Sixth Circuit archive. The full published opinion text was reviewed in a public reporter mirror and its continuing use was corroborated in the Sixth Circuit's official published Luedtke opinion. A comprehensive commercial citator was not run. ## Official source and pinpoints 473 F.3d 229 (6th Cir. 2006), 473 F.3d 231–36: ## Linked claims - `CLM-CIR6-001` ## Used in - [Sixth Circuit Overlay](https://jason93.com/legal/federal-process/modules/95-circuit-overlays/sixth-circuit.md)