---
title: "Fuller v. Rich"
citation: "11 F.3d 61 (5th Cir. 1994)"
authority_id: "AUTH-CA5-FULLER-11-F3D-61"
authority_type: "case"
jurisdiction: "federal_fifth_circuit"
precedential_status: "binding_in_ca5"
official_url: "https://www.ca5.uscourts.gov/Opinions/pub/93/93-01767.CR0.wpd.pdf"
url: "https://jason93.com/legal/federal-process/authorities/AUTH-CA5-FULLER-11-F3D-61/"
legal_review: "2026-08-25"
links_checked: "2026-10-15"
links_available: 1
links_checked_count: 1
license: "CC BY 4.0"
---

# Fuller v. Rich

## Holdings used

- A federal prisoner challenging a Parole Commission decision must exhaust before § 2241 review; exceptions are confined to extraordinary circumstances and the prisoner bears the burden.

## Material limitation

Binding only in the Fifth Circuit and only for the bounded procedural postures in the linked claims. Official published opinion reviewed. The administrative system was the Parole Commission appeal process, not BOP Part 542. A comprehensive commercial citator was not run.

## Official source and pinpoints

11 F.3d 61 (5th Cir. 1994), 11 F.3d 62: <https://www.ca5.uscourts.gov/Opinions/pub/93/93-01767.CR0.wpd.pdf>

## Linked claims

- `CLM-CIR5-001`


## Used in

- [Fifth Circuit Overlay](https://jason93.com/legal/federal-process/modules/95-circuit-overlays/fifth-circuit.md)
