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Eleventh Circuit Finds Disabled Prisoner in Imminent Danger for Filing Fee Purposes
by David M. Reutter
The Eleventh Circuit Court of Appeals has vacated a Georgia federal district court’s injunction that prohibited a prisoner from submitting future filings, and reversed the lower court’s dismissal of the prisoner’s complaint.
Before the Eleventh Circuit was the appeal of Georgia prisoner Tracy A. Miller, incarcerated at the Augusta State Medical Prison (ASMP). Miller is a paraplegic confined to a wheelchair. He alleged in his civil rights complaint that prison officials had failed to make adequate accommodations for his medical limitations, which subjected him to physical harm.
Specifically, he claimed that prison officials had ignored his kidney condition, which requires catheter treatment and medication, and his chronic high blood pressure, which requires medication. As an example of the officials’ disregard for his medical condition, Miller stated he was confined for twenty-four hours a day in a cell too small for him to move his wheelchair and was denied accessible toilets and urine catheters, thereby forcing him to lie in his own bodily waste.
Since he lacked sufficient funds to pay the filing fee for his complaint, Miller proceeded in forma pauperis (IFP). Although he was a “frequent filer” who had had enough previous cases dismissed as frivolous to fall under the three-strikes provision of 28 U.S.C. § 1915(g), Miller argued that his claim of mistreatment fell under the statute’s “imminent threat” exception.
The district court ruled that Miller’s latest complaint and exception argument were being used “as a means to force a shotgun blast of other frivolous and duplicative claims into court.” The court noted that Miller had two other suits pending concerning similar conditions at the Georgia State Prison and Men’s State Prison, which were duplicative of his most recent case against ASMP.
Thus, the district court found that Miller’s complaint should be dismissed as frivolous and, in an effort to curb his litigious activity, enjoined Miller from submitting further filings without first paying the $1,329 in unpaid filing fees he had accrued.
On appeal, the Eleventh Circuit said a blanket injunction prohibiting all IFP filings by a given party would be overinclusive, as it could screen out legitimate claims even if those claims concerned fundamental rights. For this reason, Congress deliberately included the “imminent threat of physical injury” exception when crafting the three-strikes provision of the Prison Litigation Reform Act (PLRA).
While judges have authority to protect their jurisdiction from abusive litigants, the Court of Appeals found the injunction imposed by the district court in Miller’s case had exceeded “the bounds of discretion” and failed to uphold Miller’s right of access to the courts. The Eleventh Circuit said it was hesitant to supplement the rules and remedies that Congress provided by statute. Therefore, Miller’s claim that he faced physical harm must be accepted as true for IFP purposes.
Finding the injunction was improper and must be vacated, the appellate court then turned to the district court’s order of dismissal. Although Miller’s two other pending suits raised claims that were “strikingly similar” to the allegations in his complaint against ASMP, that did not mean the conditions at ASMP were not similarly abusive. The other lawsuits were found to have an “arguable basis in law,” so there was no reason for the district court to view the same conditions at another prison skeptically. Thus, as Miller’s core claims had passed the threshold in his two other pending cases, they likewise stated a claim in his complaint involving ASMP.
Accordingly, the district court’s order of dismissal was reversed and its injunction against future filings was vacated, and the case remanded for further proceedings. See: Miller v. Donald, 541 F.3d 1091 (11th Cir. 2008).
The Eleventh Circuit Court of Appeals has vacated a Georgia federal district court’s injunction that prohibited a prisoner from submitting future filings, and reversed the lower court’s dismissal of the prisoner’s complaint.
Before the Eleventh Circuit was the appeal of Georgia prisoner Tracy A. Miller, incarcerated at the Augusta State Medical Prison (ASMP). Miller is a paraplegic confined to a wheelchair. He alleged in his civil rights complaint that prison officials had failed to make adequate accommodations for his medical limitations, which subjected him to physical harm.
Specifically, he claimed that prison officials had ignored his kidney condition, which requires catheter treatment and medication, and his chronic high blood pressure, which requires medication. As an example of the officials’ disregard for his medical condition, Miller stated he was confined for twenty-four hours a day in a cell too small for him to move his wheelchair and was denied accessible toilets and urine catheters, thereby forcing him to lie in his own bodily waste.
Since he lacked sufficient funds to pay the filing fee for his complaint, Miller proceeded in forma pauperis (IFP). Although he was a “frequent filer” who had had enough previous cases dismissed as frivolous to fall under the three-strikes provision of 28 U.S.C. § 1915(g), Miller argued that his claim of mistreatment fell under the statute’s “imminent threat” exception.
The district court ruled that Miller’s latest complaint and exception argument were being used “as a means to force a shotgun blast of other frivolous and duplicative claims into court.” The court noted that Miller had two other suits pending concerning similar conditions at the Georgia State Prison and Men’s State Prison, which were duplicative of his most recent case against ASMP.
Thus, the district court found that Miller’s complaint should be dismissed as frivolous and, in an effort to curb his litigious activity, enjoined Miller from submitting further filings without first paying the $1,329 in unpaid filing fees he had accrued.
On appeal, the Eleventh Circuit said a blanket injunction prohibiting all IFP filings by a given party would be overinclusive, as it could screen out legitimate claims even if those claims concerned fundamental rights. For this reason, Congress deliberately included the “imminent threat of physical injury” exception when crafting the three-strikes provision of the Prison Litigation Reform Act (PLRA).
While judges have authority to protect their jurisdiction from abusive litigants, the Court of Appeals found the injunction imposed by the district court in Miller’s case had exceeded “the bounds of discretion” and failed to uphold Miller’s right of access to the courts. The Eleventh Circuit said it was hesitant to supplement the rules and remedies that Congress provided by statute. Therefore, Miller’s claim that he faced physical harm must be accepted as true for IFP purposes.
Finding the injunction was improper and must be vacated, the appellate court then turned to the district court’s order of dismissal. Although Miller’s two other pending suits raised claims that were “strikingly similar” to the allegations in his complaint against ASMP, that did not mean the conditions at ASMP were not similarly abusive. The other lawsuits were found to have an “arguable basis in law,” so there was no reason for the district court to view the same conditions at another prison skeptically. Thus, as Miller’s core claims had passed the threshold in his two other pending cases, they likewise stated a claim in his complaint involving ASMP.
Accordingly, the district court’s order of dismissal was reversed and its injunction against future filings was vacated, and the case remanded for further proceedings. See: Miller v. Donald, 541 F.3d 1091 (11th Cir. 2008).
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Related legal case
Miller v. Donald
| Year | 2008 |
|---|---|
| Cite | 541 F.3d 1091 (11th Cir. 2008) |
| Level | Court of Appeals |
| Injunction Status | N/A |