Coleman v. Tollefson
135 S. Ct. 1759
| SCOTUS | 2015Background
- 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)
