Justice Powell's papers on Burrell v. McCray are included in this website for what they show about Justice Powell's thinking about Section 1983, rather than because the case itself is important.  Burrell is not an important case.  While it raised an important issue—whether a prisoner claiming that his constitutional rights had been violated, should be required to exhaust his administrative remedies before suing under § 1983—the Burrell Court never reached that issue.  Instead it dismissed certiorari as improvidently granted, thus deciding not to decide the case at all. 

Powell's Burrell papers are included in this website because they provide important insights into Powell's thinking about § 1983—particularly his desire to reduce § 1983's scope and to overrule Monroe on the color of law issue.  (See, e.g., his July 31, 1975 memo “Limitations on § 1983” or his April 27, 1976 memo in which he indicates he would vote to overrule Monroe.)  

For that purpose, it is not necessary to give Burrell the comprehensive treatment given to cases like Monell or Owen.  Instead, this mini-case file contains a complete set of Justice Powell’s papers relating to Burrell, but contains nothing from any of the other justices' papers.