Williams v. Obama

Summary

The D.C. Circuit reversed the district court’s denial of Lacy L. Williams’s motion to proceed in forma pauperis under the Prison Litigation Reform Act’s three-strikes provision. The court held that its prior determination that Williams qualified for the imminent-danger exception was law of the case and bound the district court, which had assessed the same allegations and materials. The disposition was issued under D.C. Circuit Rule 36 and was not published.

Holdings

1. When the court granted Williams leave to proceed in forma pauperis on the mandamus petition after expressly addressing the three-strikes provision and the alleged medical danger, it necessarily determined that Williams met the imminent-danger exception to 28 U.S.C. § 1915(g), even though the order did not expressly state that conclusion.
2. The district court was bound by the court of appeals' prior determination that Williams qualified for the imminent-danger exception because the district court considered the same issue and the same material underlying the prior ruling.

Questions Presented

1. Whether the court's prior order granting Williams leave to proceed in forma pauperis on a mandamus petition arising from the same complaint necessarily determined that he satisfied the imminent-danger exception to 28 U.S.C. § 1915(g).
2. Whether that prior determination constituted law of the case binding the district court when it later denied Williams leave to proceed in forma pauperis in the underlying civil action.

Disposition

reversed