Jones v. Cuomo, 2 F.4th 22

Daniel Jones, convicted of sex offenses, completed his criminal sentence in 2012 but was civilly committed under New York Mental Hygiene Law Article 10 shortly before release and remains confined as a civil detainee.
In 2016 Jones sued under 42 U.S.C. § 1983 challenging aspects of his Article 10 commitment and confinement; the district court granted IFP but dismissed most claims and ruled remaining claims time-barred.
On appeal the Second Circuit required a Prisoner Authorization Form and, treating Jones as a PLRA "prisoner," began deducting appellate filing fees from his institutional patient account at Central New York Psychiatric Center (CNYPC).
Jones contended he was not a "prisoner" under the PLRA and moved for restoration of the fees deducted during the appeal.
The Second Circuit held Jones was not a "prisoner" under 28 U.S.C. § 1915(h) at the time he filed suit because his detention was civil—based on a mental abnormality finding—not the result of a criminal conviction or related supervision, and ordered refund of the improperly deducted fees and cessation of further collections.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Jones was a "prisoner" under the PLRA when he filed his suit	Jones: he was a civil detainee under Article 10, not a prisoner, so PLRA fee deductions do not apply	Court/administration treated him as a prisoner for fee collection because he was confined in an institutional setting and had prior criminal convictions	The PLRA applies only to those detained as a result of a criminal accusation, conviction, or related supervision; Jones was civilly detained and thus not a PLRA "prisoner"
Whether erroneously deducted PLRA fees can be refunded despite sovereign immunity concerns	Jones: fees were taken improperly and should be restored to his patient account	Government: prior precedent (Goins) suggests sovereign immunity can bar recovery when funds were collected under statutory authority	Court distinguished Goins, concluded fees were wrongly deducted and ordered refund and cessation of further collections

Gibson v. City Municipality of New York, 692 F.3d 198 (2d Cir. 2012) (holding the relevant time to determine "prisoner" status is when the complaint is filed)
Page v. Torrey, 201 F.3d 1136 (9th Cir. 2000) (interpreting PLRA definition and noting broad readings would overreach)
Jackson v. Johnson, 475 F.3d 261 (5th Cir. 2007) (distinguishing criminal detainees from other detainees under the PLRA)
Michau v. Charleston Cnty., 434 F.3d 725 (4th Cir. 2006) (holding detainees under civil sex-offender statutes are not "prisoners" for PLRA purposes)
Merryfield v. Jordan, 584 F.3d 923 (10th Cir. 2009) (same conclusion for civilly detained sex offenders)
Troville v. Venz, 303 F.3d 1256 (11th Cir. 2002) (similar holding regarding civil detainees and PLRA applicability)
Goins v. Decaro, 241 F.3d 260 (2d Cir. 2001) (discussing limits on recoupment of PLRA-collected funds due to sovereign immunity; distinguished here)
Jones v. Smith, 720 F.3d 142 (2d Cir. 2013) (illustrating refunds when PLRA fees were improperly deducted from non-applicable detainees)