Cotton v. New York State Office, No. 20-1644 (2d Cir. 2024)
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The plaintiff-appellant, Maurice Cotton, an inmate, filed a civil rights lawsuit against corrections officials at the Green Haven Correctional Facility. He alleged that he was wrongfully denied a transfer to another prison facility and retaliated against for filing grievances related to the transfer request. Cotton sought permission to proceed in forma pauperis (IFP), which allows indigent prisoners to pay filing fees through a structured payment plan linked to their prison accounts. The district court denied Cotton's IFP request, concluding that he had accumulated "at least three" strikes under the Prison Litigation Reform Act (PLRA) due to previous lawsuit dismissals.
The United States Court of Appeals for the Second Circuit vacated and remanded the district court's decision, ruling that the district court erred in its interpretation of the three previous lawsuits. According to the appellate court, not all of Cotton's previous lawsuits counted as PLRA strikes. The court further explained that a dismissal under Heck v. Humphrey does not automatically count as a PLRA strike, arguing that the key consideration is whether the dismissal is based on the merits of the case or if it was merely a matter of timing or sequencing. Therefore, the appellate court concluded that the district court incorrectly denied Cotton's request for IFP status, warranting a remand for further proceedings.
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