History
  • No items yet
midpage
Coleman v. Tollefson
135 S. Ct. 1759
| SCOTUS | 2015
Read the full case

Background

  • Coleman, a state prisoner, filed three federal suits dismissed as frivolous or for failure to state a claim under §1915(g).
  • While appealing the third dismissal, he filed four additional federal suits seeking in forma pauperis status.
  • District court and Sixth Circuit held that a prior §1915(g) dismissal counts as a strike even if pending on appeal.
  • Constitutionality of counting a dismissal during appeal was contested; Coleman urged only final dispositions should count.
  • The Court held that a prior dismissal counts as a strike even when an appeal is pending, baring in forma pauperis status for new actions.

Issues

Issue Plaintiff's Argument Defendant's Argument Held
Whether a §1915(g) dismissal counts as a strike while appeal is pending Coleman argues pending appeal should delay counting Respondents argue dismissal counts immediately Counts as strike despite pending appeal

Key Cases Cited

  • Adkins v. E. I. Du Pont de Nemours & Co., 335 U.S. 331 (U.S. 1948) (access to justice despite poverty; early in forma pauperis statute context)
  • Neitzke v. Williams, 490 U.S. 319 (U.S. 1989) (filtration of frivolous prisoner suits)
  • Jones v. Bock, 549 U.S. 199 (U.S. 2007) (statutory three-strikes aim to filter bad claims)
  • Heintz v. Jenkins, 514 U.S. 291 (U.S. 1995) (dismissal language and appellate context)
  • Clay v. United States, 537 U.S. 522 (U.S. 2003) (finality and preclusion effects of judgments)
Read the full case

Case Details

Case Name: Coleman v. Tollefson
Court Name: Supreme Court of the United States
Date Published: May 18, 2015
Citation: 135 S. Ct. 1759
Docket Number: 13–1333.
Court Abbreviation: SCOTUS