--- title: "Richmond v. Scibana" citation: "387 F.3d 602 (7th Cir. 2004)" authority_id: "AUTH-CA7-RICHMOND-387-F3D-602" authority_type: "case" jurisdiction: "federal_seventh_circuit" precedential_status: "binding_in_ca7" url: "https://jason93.com/legal/federal-process/authorities/AUTH-CA7-RICHMOND-387-F3D-602/" legal_review: "2026-08-25" links_checked: "2026-10-15" links_available: 1 links_checked_count: 1 license: "CC BY 4.0" --- # Richmond v. Scibana ## Holdings used - A common-law exhaustion rule applies to § 2241; exceptions exist but the hurdle is high, and a prisoner cannot manufacture exigency by delay. ## Material limitation Binding only in the Seventh Circuit and only for the bounded procedural postures in the linked claims. The original 2004 opinion was not located in the current official Seventh Circuit archive. The full published opinion text was reviewed in a public reporter mirror and the exact exhaustion rule was corroborated in a later official Seventh Circuit disposition. A comprehensive commercial citator was not run. ## Official source and pinpoints 387 F.3d 602 (7th Cir. 2004), 387 F.3d 604–06: ## Linked claims - `CLM-CIR7-001` ## Used in - [Seventh Circuit Overlay](https://jason93.com/legal/federal-process/modules/95-circuit-overlays/seventh-circuit.md)