With no explanation, chose the best option from "A", "B", "C" or "D". Litigation Reform Act of 1995 (PLRA), 42 U.S.C. § 1997e(a). It did not hold, however, that an inmate’s failure to exhaust administrative remedies deprived courts of subject matter jurisdiction over a 28 U.S.C. § 2241 petition or any other type of claim. 2 . Skinner and "Winck mention Gonzalez’s holding only in dicta. Skinner, 355 F.3d at 1295; "Winck, 327 F.3d at 1300 n. 1. Lucas and Mitchell predate Gonzalez and do not address § 2241 petitions at all. Lucas, 898 F.2d at 1555; Mitchell, 845 F.2d at 952-53. 3 . Beginning in 2005, 13 years after Gonzalez was decided, Congress enacted a series of amendments to § 2241 aimed at limiting the jurisdiction of courts to hear § 2241 petitions brought by aliens detained as enemy combatants. See Pub.L. No. 109-148, § 1005(e)(1), 119 th Cir.2009) (<HOLDING>); United States v. Archer, 531 F.3d 1347, 1352

A: holding that filing of an administrative complaint did not meet the requirement that the employee seek counseling prior to filing
B: holding that appellate deadlines are stayed during pendency of automatic stay imposed by insurance code
C: holding that one of our prior panel precedents about when criminal filing deadlines are jurisdictional was abrogated by bowles v russell 551 us 205 127 sct 2360 168 led2d 96 2007 even though bowles dealt with civil filing deadlines
D: holding that one of our prior panel precedents involving the armed career criminal act was undermined to the point of abrogation by shepard v united states 544 us 13 125 sct 1254 161 led2d 205 2005 even though shepard dealt with a different provision of that act
C.