Federal inmate Michael C. Antonelli, who is currently serving sentences for a 1997 bank fraud and a 2001 bank robbery at the United States Penitentiary in Beau
Because Antonelli filed his “motion” under the district-court cause number of his 25-year-old criminal case and even captioned the United States as the
'plaintiff,
the district court understandably appears to have viewed the filing as an additional motion in that long-finished proceeding. When determining the character of a pro se filing, however, courts should look to the substance of the filing rather than its label.
Gleash v. Yuswak,
Because Antonelli’s filing is appropriately seen as an attempt to commence a new civil suit, the PLRA subjected him to significant procedural constraints and potential consequences that he in effect evaded by using his old criminal case number.
See United States v. Howell,
The PLRA seeks to balance an inmate’s right of access to the courts against both the heed to curtail frivolous litigation that overwhelms the judicial system and the benefit of giving prison officials the first opportunity to address problems in the system.
See Kincade v. Sparkman,
Accordingly, although we in no way suggest disagreement with the district court’s evaluation of the merits of Antonelli’s claim, we conclude that the district court should not have reached the merits without first enforcing the PLRA.
Cf. Sloan v. Lesza,
