In Re Buddhi
2011 U.S. App. LEXIS 18673
| 7th Cir. | 2011Background
- Buddhi, a pro se defendant, challenged the district court's denial of his sentence-related motion and sought mandamus to stop applying prison-account funds to a filing fee and a special assessment.
- The district court allowed Buddhi to proceed in forma pauperis, but later required $300.67 toward the filing fee and ordered the warden to deduct the unpaid balance of a $1100 special assessment from his prison trust account (balance $1067).
- Although Buddhi had deposited $1501.83 in the six months before, he had not made payments toward the filing fee, triggering 28 U.S.C. § 1915(b)(2) consequences.
- The district court based the filing-fee deduction on proper authority, but the special-assessment deduction relied on an override of Buddhi's payment plan under the Inmate Financial Responsibility Program.
- The Attorney General, not the courts, is responsible for collecting unpaid fines/restitution, through the Bureau of Prisons, and Buddhi’s plan was to pay $25 per quarter toward the balance; the judgment had required immediate payment.
- The Seventh Circuit ultimately denied the mandamus petition, holding the warden deduction was improper, but affirming that the filing-fee deduction was proper and that the district court exceeded its authority only as to the special-assessment deduction.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| May the district court deduct the unpaid filing fee from Buddhi's prison account? | Buddhi argues courts cannot collect filing fees from prison funds. | District court can order payment from the trust account under 28 U.S.C. § 1915(b)(2). | Yes; filing-fee deduction was proper. |
| Did the district court have authority to override Buddhi's payment plan to deduct the special assessment? | Buddhi contends the court cannot override the payment plan and collect more than planned. | District court may adjust payments under 18 U.S.C. § 3572(d)(3) and collect as fines. | No; district court exceeded its authority; the warden's deduction should be rescinded. |
| Who has ultimate authority to collect unpaid fines and special assessments? | AG/BOP collection is appropriate via Inmate Financial Responsibility Program. | Court interference is not permitted; collection is delegated to the Bureau of Prisons. | The Attorney General/BOP collection is proper and courts cannot override discretion. |
| Is Buddhi entitled to mandamus relief to rescind the order? | Buddhi seeks mandamus to stop improper deductions. | The district court's actions related to the filing fee were proper; the rest was disputed. | Denied. |
Key Cases Cited
- Lucien v. DeTella, 141 F.3d 773 (7th Cir. 1998) (separately recognizing proper collection authority over certain orders)
- United States v. Ellis, 522 F.3d 737 (7th Cir. 2008) (delegation of collection authority to the Bureau of Prisons)
- Matheny v. Morrison, 307 F.3d 709 (8th Cir. 2002) (delegation and administrative practicality of collection)
- McGhee v. Clark, 166 F.3d 884 (7th Cir. 1999) (discusses enlargement or acceleration of payment obligations)
- United States v. Sawyer, 521 F.3d 792 (7th Cir. 2008) (court cannot override prison administration details)