Chase v. Coalinga State Hospital

Summary

The United States District Court for the Eastern District of California grants Harry Chase’s non-prisoner application to proceed in forma pauperis in an action under 42 U.S.C. § 1983. The court explains that, as a civil detainee, Plaintiff is not a prisoner under the Prison Litigation Reform Act and therefore is not required to submit a prisoner trust-account statement or exhaust administrative remedies.

Holdings

1. Plaintiff's declaration made the showing required by 28 U.S.C. § 1915(a), so his application to proceed in forma pauperis was granted.
2. A civil detainee is not a prisoner within the meaning of the Prison Litigation Reform Act and therefore is not required to provide a prisoner trust-fund account statement or exhaust administrative remedies, so long as the detainee status remains unchanged.

Questions Presented

1. Whether Plaintiff demonstrated eligibility to proceed in forma pauperis under 28 U.S.C. § 1915(a).
2. Whether a civil detainee is a prisoner for purposes of the Prison Litigation Reform Act's trust-account and administrative-exhaustion requirements.

Disposition

other