Coleman v. Tollefson (2014)
- Docket
- 13-1333
- Decided
- 2014-01-01
Summary
Question: Does a district court's dismissal of a lawsuit counts as a "strike" under the PLRA while it is still pending on appeal? Conclusion: Yes. Justice Stephen G. Breyer delivered the opinion for the unanimous Court, which held that a plain reading of the Prison Litigation Reform Act (PLRA) indicates that a dismissal is a “strike” for the purpose of the “three strikes” provision when the case is pending on appeal. The text of the statute refers to when an action is “dismissed,” which does not normally include subsequent activity on appeal. A reading of the statute that does not include appellate action within the meaning of “dismissed” is consistent with the rest of the statute, which treats trials and appeals separately, and with the statute’s purpose of filtering out bad claims. The Court also held that there was little risk that a prisoner would erroneously be denied in forma pauperis status.