Sanders v. Melvin, No. 20-3276 (7th Cir. 2022)
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Sanders, a severely mentally ill inmate, has been in the custody of the Illinois Department of Correction since 2004. For eight years, he was in solitary confinement, where his mental health deteriorated. Sanders has attempted suicide and engaged in self-harm multiple times. He claims that self-mutilation was a pre-condition for solitary confinement inmates to speak with a mental health person. Sanders filed suit and applied to proceed in forma pauperis (IFP), which allows indigent prisoners to bring suits without prepaying the filing fee, 28 U.S.C. 1915(g). Under the Prison Litigation Reform Act, a prisoner who has three strikes—actions or appeals dismissed for being “frivolous, malicious, or fail[ing] to state a claim”—can only proceed without prepayment if he is “under imminent danger of serious physical injury.” Sanders cited the “imminent danger exception.”
The district court initially granted his IFP application but later revoked its grant, finding that none of Sanders’s allegations demonstrated that he was in imminent danger. The Seventh Circuit reinstated his IFP status. Sanders adequately alleged his belief that certain practices at the Pontiac Correctional Center would lead him to self-harm. The district court erroneously determined that the allegations were fraudulent and did so without explicitly considering whether lesser sanctions would be appropriate.
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