Ryan Scott Adams v. Mabury, et al.

Summary

The court overruled Ryan Scott Adams’s untimely objections to the denial of in forma pauperis status under the Prison Litigation Reform Act’s three-strikes rule. It held that the prior dismissal in Adams v. Jackson remained a qualifying strike, rejected the argument that strikes expire after one year, and ordered Adams to pay the $405 filing fee by December 24, 2025.

Holdings

1. Section 1915(g) contains no temporal limitation requiring qualifying strikes to have occurred within the preceding year; an older qualifying dismissal may count as a strike.
2. A prior dismissal on a statutorily enumerated ground counts as a PLRA strike even while the dismissal is being appealed.
3. Plaintiff did not establish that § 1915(g) was inapplicable, so the court properly denied his motion to proceed in forma pauperis.

Questions Presented

1. Whether a dismissal qualifying as a PLRA strike must have occurred within the preceding year to bar a prisoner from proceeding in forma pauperis.
2. Whether a qualifying dismissal remains a PLRA strike while the prisoner's appeal of that dismissal is pending.
3. Whether the plaintiff's untimely objections established that he should not be denied in forma pauperis status under 28 U.S.C. § 1915(g).

Disposition

other