BROWN v. ZAKEN

District Court, W.D. Pennsylvania·Decided April 4, 2025·No. 2:23-cv-01649·Unknown

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF PENNSYLVANIA PITTSBURGH DIVISION RAYMOND BROWN, ) ) Civil Action No.: ) 2:23-CV-01649-CBB-MRH Plaintiff, ) ) vs. ) United States Magistrate Judge ) Christopher B. Brown CORRECTIONAL OFFICER C. ) ) FOWLER, COORECTIONAL SGT. ) JOHN DOE, SUED INDIVIDUALLY ) AND IN OFFICIAL CAPACITY; AND ) COORECTIONAL OFFICER JOHN ) ) FOE, ) ) Defendants. )

MEMORANDUM OPINION1 REVOKING STATUS

Christopher B. Brown, United States Magistrate Judge. I. Introduction Plaintiff Raymond Brown is a state prisoner in the custody of the Pennsylvania Department of Corrections and currently incarcerated at SCI- Phoenix. Before the Court is Defendant C. Fowler’s motion to vacate order on motion for leave to proceed (“IFP”). ECF No. 75. The motion is fully briefed and ripe for disposition. ECF Nos. 76, 79, 80. For the reasons that follow, the Court will grant Defendant Fowler’s motion, revoke Brown’s IFP status

1 A motion to proceed is a non-dispositive motion and appropriately decided by a federal magistrate judge. , 76 F.4th 184, 195–98 (3d Cir. 2023) (concluding an IFP motion is a non-dispositive pretrial motion and, as such, magistrate judges maintain jurisdiction to decide an IFP motion). and dismiss this action without prejudice to Brown reopening it by paying the full statutory and administrative filing fees totaling $405.00.2 I. Factual Background

This action was initiated on September 15, 2023 by Brown submitting an IFP motion. ECF No. 1. His original motion was denied as insufficient and he again filed a motion to proceed IFP which the Court granted. ECF Nos. 6, 9. Distilled to its essence, Brown’s operative complaint alleges that he was subjected to loud music and a loud vehicle interior during a seven-hour transport from SCI-Smithfield to SCI-Greene which caused pain, suffering and hearing loss. ECF No. 60 at ¶¶ 6-24.

After the Court granted in part and denied in part Defendants’ motion to dismiss, and allowed Brown to file a second amended complaint, this case proceeded to discovery. ECF No. 65. On January 7, 2025, Brown filed a motion for injunctive relief to prevent Defendants from transporting him in a lockbox and on a bus. ECF No. 66. Thereafter, on January 15, 2025, this Court entered a briefing order requiring the parties to brief whether Brown’s IFP status should be revoked, as it

came to the attention of the Court that he filed several other 42 U.S.C. § 1983 cases about the conditions of his confinement under several different names, including “R. Brown,” “Raymon Brown,” “Raymond Scott Brown,” “Cordiro Raymond Brown,” “Cordiro R. Brown,” and “Raymond Cordiro Brown” and because several other

2 The filing fee is $350.00 plus a $55.00 administrative fee, for a total of $405.00. https://www.pawd.uscourts.gov/fee-schedule. courts had found that Brown was three-struck from proceeding IFP under 28 U.S.C. § 1915(g) several years before he initiated this action. ECF No. 68. II. The Prison Litigation Reform Act and the Three Strikes Rule

The IFP statute, 28 U.S.C. § 1915, allows indigent litigants to bring an action in federal court without prepayment of filing fees, ensuring that such persons are not prevented “from pursuing meaningful litigation” because of their indigence. , 239 F.3d 307, 312 (3d Cir. 2001) (en banc) (internal quotation marks omitted), 533 U.S. 953 (2001). “[I]n response to the tide of substantively meritless prisoner claims that have swamped the federal courts,” Congress enacted the Prison Litigation Reform Act (“PLRA”) in 1996.

, 726 F.3d 448, 452 (3d Cir. 2013) (cleaned up), , 575 U.S. 532 (2015). Among other things, the PLRA implemented the so-called “three strikes rule,” which provides: In no event shall a prisoner bring a civil action or appeal a judgment in a civil action or proceeding under this section if the prisoner has, on 3 or more prior occasions, while incarcerated or detained in any facility, brought an action or appeal in a court of the United States that was dismissed on the grounds that it is frivolous, malicious, or fails to state a claim upon which relief may be granted, unless the prisoner is under imminent danger of serious physical injury.

28 U.S.C. § 1915(g). Thus, under the PLRA, prisoners with three prior strikes can proceed IFP only if they are in imminent danger of serious physical injury. “[A] strike under § 1915(g) will accrue only if the entire action or appeal is (1) dismissed explicitly because it is ‘frivolous,’ ‘malicious,’ or ‘fails to state a claim’ or (2) dismissed pursuant to a statutory provision or rule that is limited solely to

dismissals for such reasons, including (but not necessarily limited to) 28 U.S.C. §§ 1915A(b)(1), 1915(e)(2)(B)(i), 1915(e)(2)(B)(ii), or Rule 12(b)(6) of the Federal Rules of Civil Procedure.” , 715 F.3d 117, 126 (3d Cir. 2013). “A strike-call under Section 1915(g) . . . hinges exclusively on the basis for the dismissal, regardless of the decision’s prejudicial effect.” , 590 U.S. –, 140 S. Ct. 1721, 1724-1725 (2020). In other words, “a prisoner accrues a strike for any action dismissed on the ground that it fails to state a claim upon which relief

may be granted” and applies to dismissals “issued both with and without prejudice to a plaintiff’s ability to reassert his claim in a later action.” . at 1724 (cleaned up). That said, “mixed dismissals – where a district court dismisses a prisoner’s federal claims on grounds enumerated in § 1915(g) and declines to exercise supplemental jurisdiction over the prisoner’s state law claims” do not count as strikes. , 15 F.4th 275, 279 (3d Cir. 2021).

Prisoners with three strikes who cannot satisfy the imminent danger exception are not barred from filing additional federal actions, rather they are denied the privilege of proceeding IFP and must pay the requisite filing fee in full prior to commencing a new action. , 239 F.3d at 314. Thus, when denying or revoking a prisoner’s IFP status because of the accrual of three strikes, the Court must determine what strikes the prisoner accrued prior to initiating the action immediately before the Court. , 160 F.3d 160, 162 (3d Cir. 1998). If determined to have three qualifying strikes to their name, then the Court must consider whether the prisoner qualifies for the “imminent danger” exception.

When deciding whether a prisoner meets the “imminent danger” exception, a Court must examine the situation faced by the prisoner at the time of the filing of the complaint, and a showing of danger in the past is insufficient to demonstrate “imminent danger.” , 239 F.3d at 312. Allegations of imminent danger must be evaluated in accordance with the liberal pleading standard applicable to pro se litigants, although the Court need not credit “fantastic or delusional” allegations that “rise to the level of the irrational or wholly incredible.”

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