Cordell Sanders v. Michael Melvin, 2017 U.S. App. LEXIS 20242

Sanders has been in solitary confinement at Pontiac for eight years, with plans for another decade.
He suffers from intermittent explosive disorder, schizoaffective disorder, and other conditions making him dangerous if granted more liberty.
Sanders brings a §1983 claim alleging that confinement harms him physically and psychologically, including asthma aggravation.
He seeks in forma pauperis status, but §1915(g) requires prepayment if he has three or more prior strikes dismissed as frivolous, malicious, or failing to state a claim.
The district court dismissed for nonpayment, citing the three-strikes rule; Sanders appeals.
The court holds that plausibility of imminent, serious physical harm may permit in forma pauperis status and remands to evaluate Sanders’s claims with factual development.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Sanders plausibly alleged imminent, serious physical harm to invoke the exception to §1915(g).	Sanders argues mental illness plus self-harm risk constitutes imminent physical harm.	Defendants contend the danger is psychological, not imminent physical harm, and the three-strikes rule applies.	Plausible allegation of imminent, serious physical harm; remand for factual development.
Whether the district court erred by treating self-serving allegations as unreliable and dismissing the claim.	Self-serving statements should not be automatically disregarded; plausibility suffices.	The district court appropriately discounted self-serving assertions as insufficient.	Court rejects automatic dismissal for self-serving pleadings; requires further factual showing.
Whether the case should be remanded to develop proof of imminent danger before resolving §1915(g) issues.	The allegations, if true, show imminent harm requiring in forma pauperis treatment pending proof.	If untrue, Sanders must pay the full fee; otherwise case could be dismissed with prejudice for manipulation.	Remand to determine truth of allegations; proceed with evidentiary proceedings as needed.

Gevas v. McLaughlin, 798 F.3d 475 (7th Cir. 2015) (prison vulnerability and risk contexts in imminent danger analysis)
Hill v. Tangherlini, 724 F.3d 965 (7th Cir. 2013) (reaffirms that pleadings must be evaluated for plausibility, not mere self-serving assertions)
Payne v. Pauley, 337 F.3d 767 (7th Cir. 2003) (limits on self-serving statements in pleading standards via Twombly framework)
Taylor v. Watkins, 623 F.3d 483 (7th Cir. 2010) (imminent danger requirement and pleading standards for §1915(g))
Ciarpaglini v. Saini, 352 F.3d 328 (7th Cir. 2003) (evidence and plausibility considerations in §1915(g) context)
Lujan v. Defenders of Wildlife, 504 U.S. 555 (1992) (standing requires proof of injury and causation at least when challenged)
Newlin v. Helman, 123 F.3d 429 (7th Cir. 1997) (procedural mechanisms to collect fees when strikes have occurred)
Thomas v. General Motors Acceptance Corp., 288 F.3d 305 (7th Cir. 2002) (sanctions and dismissal consequences for frivolous litigation conduct)
Ammons v. Gerlinger, 547 F.3d 724 (7th Cir. 2008) (potential sanctions and procedural consequences for frivolous filings)
Fletcher v. Menard Correctional Center, 623 F.3d 1171 (7th Cir. 2010) (jurisdictional and procedural evaluation in §1915(g) matters)