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In re Wallace

Updated Sep 20, 2026

In brief

The Supreme Court declined review, leaving the lower courts’ decision to count Wallace’s dismissal as a “strike” in place without deciding whether it was lawful.

Where it stands
Decided

Decided · May 18, 2020

What it’s about
The Court denied Wallace’s request for extraordinary relief, leaving in place the lower courts’ treatment of a prior dismissal as a “strike” under the Prison Litigation Reform Act.
Who it affects
The order left the lower courts’ decision to count Wallace’s prior dismissal as a “strike” unchanged, without deciding whether that treatment was lawful.

Summary: written with AI from the case record.

Illustration for In re Wallace
Conceptual illustration · AI-generated

What it's about

Wallace argued that a magistrate judge lacked authority to record the strike and that it improperly limited his ability to pursue an appeal.

The Prison Litigation Reform Act includes a “three strikes” rule aimed at curbing frivolous, malicious, or vexatious prisoner lawsuits.

Question presented

1. Whether the Petitioner is being held in custody in violation of the Constitution or laws or treaties of the United States? 2. Whether the Petitioner is entitled to a writ of habeas corpus?

What the Court decided

Holding

Petition DENIED.

What's next

The Supreme Court has finished this docket action. The lower-court treatment remains in place, but this order leaves the underlying legal question unresolved.

Documents

2

Docket activity

26
  • New analysis added

    Sep 20, 2026 · Court records

  • AI analysis generated: Case Briefing

    Sep 20, 2026 · Generated

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    Sep 20, 2026 · Court records

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    Sep 20, 2026 · Court records

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    Sep 19, 2026 · Court records

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    Sep 19, 2026 · Court records

Older entries are on the full docket.

More questions

1
What did Wallace argue the magistrate judge did wrong?
He argued that Magistrate Judge Nancy Koenig lacked authority to record the strike and that counting it limited his ability to pursue an appeal.

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.

Checked Sep 20, 2026Methodology

Court records and filings

Reporting and analysis