Smith v. Indiana Department of Correction

Summary

The Supreme Court of Indiana held that the state's Three Strikes Law, which generally barred an inmate from filing a new complaint after three prior dismissals under the Frivolous Claim Law, violated the Open Courts Clause of the Indiana Constitution. The court concluded that access to courts may be subject to reasonable conditions, but claims cannot be categorically barred based solely on the litigant's prior filing history without an individualized assessment of the claim's merits. The case was remanded for consideration of whether Smith's complaint should be dismissed under the Frivolous Claim Law.

Holdings

1. Indiana's Three Strikes Law violates the Open Courts Clause because it arbitrarily and unreasonably denies an offender access to the courts based solely on the offender's prior litigation history, without an individualized assessment of the merits of the new claim.
2. The Supreme Court did not decide whether Smith's complaint was subject to dismissal under the Frivolous Claim Law and remanded that issue to the trial court.

Questions Presented

1. Whether Indiana's Three Strikes Law, which barred an offender who had accumulated three dismissals under the Frivolous Claim Law from filing another complaint absent immediate danger of serious bodily injury, violated article I, section 12 of the Indiana Constitution's Open Courts Clause.
2. Whether the complaint should instead be dismissed under Indiana's Frivolous Claim Law.

Disposition

reversed_and_remanded