Snell v. Tuolumne County

Summary

The United States District Court for the Eastern District of California denied Michael Snell’s motion to vacate orders and remove the magistrate judge from his § 1983 action against Tuolumne County and others. The court held that the referral to the magistrate judge was authorized and that the plaintiff was required to pay filing fees under 28 U.S.C. §§ 1914 and 1915, although payment could occur over time under the in forma pauperis provisions.

Holdings

1. A referral to a magistrate judge under 28 U.S.C. § 636(b)(1)(B) and Local Rule 302 is lawful; a party's lack of consent does not make the referral or the court's orders void.
2. An inmate may commence an action without prepaying the filing fee in full when authorized to proceed in forma pauperis, but remains obligated to pay the entire filing fee over time.

Questions Presented

1. Whether the referral of the case to a magistrate judge was invalid or deprived the court of subject-matter jurisdiction because plaintiff had not consented to magistrate-judge jurisdiction.
2. Whether plaintiff had a constitutional or other legal right to proceed without paying filing fees.
3. Whether the court's orders were void and subject to vacatur on those grounds.

Disposition

other