Sanders v. Melvin

Dist. Ct. erred in dismissing plaintiff-prisoner’s lawsuit alleging that defendants-prison officials were deliberately indifferent to his mental health needs as sanction for, according to Dist. Ct., making unfounded allegations that his continued confinement in solitary confinement and other actions presented him with danger of serious physical injury/self harm so as to support his request to avoid having to prepay filing fees, where plaintiff already had “three strikes” under Prison Litigation Reform Act. While Dist. Ct. held belief that plaintiff had committed “fraud” when making said allegations, Ct. of Appeals, in reversing Dist. Ct., noted record contained 100 pages of mental health notes that supported plaintiff’s claim of attempted suicides and otherwise did not refute plaintiff’s claims of being in potential danger of serious personal injury so as to allow him to proceed without prepaying filing fee. Alternatively, Ct. of Appeals held that even if medical records did not support plaintiff’s claims, it was still error to conclude that plaintiff’s inaccurate claims constituted sanctionable lie, where Dist. Ct. did not make any finding that plaintiff had acted intentionally or in bad faith when making his claims. Moreover, due to plaintiff’s pro se status, Dist. Ct. was required to hold plaintiff to less stringent pleading standards, and Dist. Ct. further erred in failing to consider any lesser sanction.