E.J. McElroy v. Sgt. Guzman, et al.

McElroy v. Guzman · United States District Court for the Eastern District of California · August 12, 2025 · No. 1:25-cv-0748 JLT GSA (PC)

Summary

The United States District Court for the Eastern District of California adopted the magistrate judge’s findings and recommendations concerning E.J. McElroy’s motion to proceed in forma pauperis. Because Plaintiff had accrued three qualifying strikes under 28 U.S.C. § 1915(g) and did not show imminent danger of serious physical injury, the Court denied pauper status and ordered him to pay the $405 filing fee within 21 days.

Court
United States District Court for the Eastern District of California
Writing for the Court
Jennifer L. Thurston
Jurisdiction
United States District Court for the Eastern District of California
Decision date
August 12, 2025
Docket number
1:25-cv-0748 JLT GSA (PC)
Procedural posture
Plaintiff moved to proceed in forma pauperis in a prisoner civil-rights action. A magistrate judge issued findings and recommendations concluding that Plaintiff had three qualifying strikes under 28 U.S.C. § 1915(g) and had not shown that he was in imminent danger of serious physical injury. Plaintiff filed no objections after receiving an extension of time, and the district court reviewed and adopted the findings and recommendations.
Standard of review
De novo review under 28 U.S.C. § 636(b)(1).
Precedential value
Unpublished district court order; precedential status not stated in the opinion.
Disposition
other

Topics

prisoners rightscivil rightscivil procedure

Practice areas

prisoner civil rightscivil procedurein forma pauperis proceedings

Questions Presented

  1. Whether Plaintiff qualified to proceed in forma pauperis despite three qualifying strikes under 28 U.S.C. § 1915(g).
  2. Whether Plaintiff alleged facts sufficient to invoke the imminent-danger exception to the three-strikes rule.
  3. Whether the magistrate judge's findings and recommendations should be adopted after Plaintiff filed no objections.

Holdings

  1. Plaintiff was not entitled to proceed in forma pauperis because he had three prior actions qualifying as strikes under 28 U.S.C. § 1915(g).
  2. Plaintiff did not allege facts supporting a finding that he was in imminent danger of serious physical injury when he filed the action.
  3. The court adopted the findings and recommendations in full after conducting de novo review under 28 U.S.C. § 636(b)(1).

Key quotations

failure to file objections within the specified time may result in the waiver of certain rights on appeal. (at 2)

Factual background

Plaintiff alleged that his civil rights were violated while he was housed at Kern Valley State Prison. He sought to proceed without prepaying the filing fee. The magistrate judge determined that Plaintiff had three prior actions dismissed for reasons qualifying as strikes under 28 U.S.C. § 1915(g), and that Plaintiff did not allege facts showing imminent danger of serious physical injury when he filed this action.

Procedural history

Plaintiff filed a civil-rights action arising from his confinement at Kern Valley State Prison and moved to proceed in forma pauperis. The magistrate judge recommended denying in forma pauperis status and requiring payment of the filing fee. After the objection period expired without objections, the district court conducted de novo review, adopted the findings and recommendations in full, denied the motion, and ordered Plaintiff to pay the $405 filing fee within 21 days, subject to dismissal without prejudice for nonpayment.

Court Document

Open PDF
Loading document…