Congress passed the Prison Litigation Reform Act (PLRA) in 1995. Since that time, no provision of the PLRA has created more confusion than the limitation-on-recovery provision, or § 1997e(e), commonly referred to as the “physical-injury requirement.” The provision reads: “No Federal civil action may be brought by a prisoner confined in a jail, prison, or other correctional facility, for mental or emotional injury suffered while in custody without a prior showing of physical injury.” Because the statute itself does not define physical injury, the provision leaves the task of defining the phrase to the courts. . . .
