Gay v. Chandra

In action by plaintiff-prisoner alleging that defendants-prison mental health officials were deliberately indifferent to plaintiff-prisoner's mental health needs, Dist. Ct. abused its discretion by requiring plaintiff to post $1,000 bond to cover defendants' costs if plaintiff's lawsuit proved to be unsuccessful, where record showed that Dist. Ct. was aware that plaintiff had no means to acquire said bond, and where Dist. Ct. ultimately dismissed case with prejudice when plaintiff failed to post said bond. Dist. Ct. should have considered plaintiff's ability to pay for said bond prior to requiring that he post said bond, and imposition of bond under instant circumstances constituted denial of access to federal court. Ct. additionally observed that there were other avenues to address perception that plaintiff had pursued vexatious litigation such as imposition of monetary sanctions or institution of future filing ban.