In re Wallace
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.

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
Docket activity
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AI analysis generated: Case Briefing
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More questions
- 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.