Where a federal statute —such as 42 U.S.C . § 1997e(a) —mandates that a plaintiff exhaust administrative remedies prior to filing suit , does the plaintiff's claim accrue only upon completion of mandatory exhaustion (as five cir cuits hol d), or does it accrue before the completion of mandatory exhaustion , such that the limitations period can expire while the plaintiff is still prohibited by statute from filing his claim in court (as the Ninth Circuit held) ?

When does a claim accrue under the Prison Litigation Reform Act's mandatory exhaustion requirement?