has yet to address this issue, but it is widely held that “prisoner” means someone confined, incarcerated, or detained, not a former prisoner. See Abdul-Akbar v. McKelvie, 239 F.3d 307, 314 (3rd Cir.2001); Janes v. Hernandez, 215 F.3d 541, 543 (5th Cir.2000); Page v. Torrey, 201 F.3d 1136, 1140 (9th Cir.2000); Harris v. Garner, 216 F.3d 970, 981 (11th Cir.2000); Greig v. Goord, 169 F.3d 165, 167 (2nd Cir.1999); Kerr v. Puckett, 138 F.3d 321, 323 (7th Cir.1998); Doe v. McKee, 150 F.3d 920, 924 (8th Cir.1998). Smith, 227 F.Supp.2d at 675. This Court agrees with that observation and further holds that there is no principled way to construe one section to include only current prisoners and expand the other to apply to former prisoners. This Court has held 82 F.3d 532, 536 (7th Cir.1999) (<HOLDING>); Jenkins v. Haubert, 179 F.3d 19, 29 (2d
recognizing that issue exhaustion requirement and requirement exhaustion of remedies are different holding that the plras exhaustion requirement contains a procedural default component holding that the plras exhaustion requirement applies to the grievance procedures set forth in an inmate handbook holding that plras exhaustion requirement is an affirmative defense that can be waived or forfeited by defendants holding that exhaustion requirement in bj997ea is an affirmative defense that may be waived or forfeited