What is the effect of improper exhaustion in the context of a wrongful death claim?

^[3] See Woodford v. Ngo, 548 U.S. 81, 94-95 (2006) ([P]roper exhaustion improves the quality of those prisoner suits that are eventually filed because proper exhaustion often results in the creation of an administrative record that is helpful to the court. When a grievance is filed shortly after the event giving rise to the grievance, witnesses can be identified and questioned while memories are still fresh, and evidence can be gathered and preserved.).