Prisoner lawsuit strikes on appeal
Andre Lee Coleman v. Tollefson
In brief
The Supreme Court agreed with the Sixth Circuit: an appeal does not keep a qualifying dismissal from counting as a strike.
- Where it stands
- Decided
Decided 9-0 · May 18, 2015 · Opinion by Justice Breyer
- What it’s about
- The Supreme Court unanimously upheld the Sixth Circuit’s ruling that a federal court’s dismissal of a prisoner’s case as frivolous, malicious, or legally insufficient counts as a “strike” under the Prison Litigation Reform Act even while the dismissal is being appealed.
- Who it affects
- Coleman's dismissal counted as a strike, so he could not proceed without prepaying court fees under the law's three-strikes rule.
Summary: written with AI from the case record.
What it's about
As a result, Andre Lee Coleman could not proceed without prepaying court fees under the law’s three-strikes rule.
The Prison Litigation Reform Act limits when prisoners can bring a case without paying court fees after three qualifying dismissals.
Question presented
Does a district court's dismissal of a lawsuit counts as a "strike" under the PLRA while it is still pending on appeal?
What the Court decided
Holding
A prior dismissal on one of §1915(g)’s statutorily enumerated grounds counts as a strike, even if the dismissal is the subject of an ongoing appeal. 733 F. 3d 175, affirmed.
- Result
- Affirmed
The vote
What's next
The Sixth Circuit's ruling remains in place, and Coleman's qualifying dismissal counts as a strike while its appeal is pending.
Documents
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Opinion added: Coleman
Sources
Primary materials plus reporting. Best-effort analysis: this explainer relies on a mix of primary materials and trusted secondary sources. Official filings and opinions remain authoritative.