Monterion D’Allen Winfrey v. Jake Rohwer, Housing Sergent at Jameson Prison Annex SDSP, individual and official capacities; Josi Schmidt, Leutenant — Officer in Command at Jameson Prison Annex SDSP, individual and official capacities; Tabitha Benting, Warden at Jameson Prison SDSP, individual and official capacities; and Tyran Wollman Housing SGT at Jameson Prison Annex, individual and official capacities

CourtDistrict Court, D. South Dakota
DecidedJune 30, 2026
Docket4:25-cv-04203
StatusUnknown

This text of Monterion D’Allen Winfrey v. Jake Rohwer, Housing Sergent at Jameson Prison Annex SDSP, individual and official capacities; Josi Schmidt, Leutenant — Officer in Command at Jameson Prison Annex SDSP, individual and official capacities; Tabitha Benting, Warden at Jameson Prison SDSP, individual and official capacities; and Tyran Wollman Housing SGT at Jameson Prison Annex, individual and official capacities (Monterion D’Allen Winfrey v. Jake Rohwer, Housing Sergent at Jameson Prison Annex SDSP, individual and official capacities; Josi Schmidt, Leutenant — Officer in Command at Jameson Prison Annex SDSP, individual and official capacities; Tabitha Benting, Warden at Jameson Prison SDSP, individual and official capacities; and Tyran Wollman Housing SGT at Jameson Prison Annex, individual and official capacities) is published on Counsel Stack Legal Research, covering District Court, D. South Dakota primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Monterion D’Allen Winfrey v. Jake Rohwer, Housing Sergent at Jameson Prison Annex SDSP, individual and official capacities; Josi Schmidt, Leutenant — Officer in Command at Jameson Prison Annex SDSP, individual and official capacities; Tabitha Benting, Warden at Jameson Prison SDSP, individual and official capacities; and Tyran Wollman Housing SGT at Jameson Prison Annex, individual and official capacities, (D.S.D. 2026).

Opinion

UNITED STATES DISTRICT COURT DISTRICT OF SOUTH DAKOTA SOUTHERN DIVISION

MONTERION D’ALLEN WINFREY, 4:25-CV-04203-CCT Plaintiff, ORDER GRANTING PLAINTIFF’S vs. MOTION FOR LEAVE TO PROCEED IN FORMA PAUPERIS AND § 1915A JAKE ROHWER, Housing Sergent [sic] SCREENING at Jameson Prison Annex SDSP, individual and official capacities; JOSI SCHMIDT, Leutenant [sic] — Officer in Command at Jameson Prison Annex SDSP, individual and official capacities; TABITHA BENTING, Warden at Jameson Prison SDSP, individual and official capacities; and TYRAN WOLLMAN Housing SGT at Jameson Prison Annex, individual and official capacities, Defendants.

Plaintiff, Monterion D’Allen Winfrey, filed a pro se civil rights lawsuit under 42 U.S.C. § 1983 while he was incarcerated at the South Dakota State Penitentiary. Docket 1. Winfrey filed a motion for leave to proceed in forma pauperis and provided the Court with a copy of his prisoner trust account report. Dockets 2, 3. I. Motion for Leave to Proceed In Forma Pauperis At the time Winfrey filed his complaint and motion to proceed in forma pauperis, he was an inmate at the South Dakota State Penitentiary, Jameson

Annex. Dockets 1, 2. But before the Court ruled on Winfrey’s motion for leave to proceed in forma pauperis, he was released from custody.! Under the Prison Litigation Reform Act (PLRA), a prisoner who “brings a civil action or files an appeal in forma pauperis... shall be required to pay the full amount of a filing fee.” 28 U.S.C. § 1915(b)(1). But circuit courts are split on whether the PLRA continues to apply after the prisoner is released during litigation. See Carson v. Tulsa Police Dep’t, 266 F. App’x 763, 766-67 (10th Cir, 2008) (describing split in authority); see also Domino v. Garland, No. 20-CV- 2983, 2021 WL 1221188, at *1 (D. Minn. Apr. 1, 2021). The United States Courts of Appeals for the Second, Fourth, and Sixth Circuits have held that, under the PLRA, “a prisoner is obligated to pay assessed fees and costs only while he or she remains incarcerated[,]” and “lajfter release, the obligation to pay the remainder of the fees is to be determined solely on the question of whether the released individual qualifies for pauper status.” In re Prison Litig. Reform Act, 105 F.3d 1131, 1139 (6th Cir. 1997); see also McGann v. Comm’r, Soc. Sec. Admin., 96 F.3d 28, 29-30 (2d Cir. 1996); DeBiasio v. Gilmore, 315 F.3d 396, 397 (4th Cir. 2003). By contrast, the Fifth, Seventh, and D.C. Circuits hold, based on the plain language of § 1915(b)(1), that a complainant must pay the full amount of the filing fee if the complainant was a prisoner when the action was commenced. See Gay v. Tex.

1 Winfrey provided the Court with a notice of change of address providing that he is no longer incarcerated. See Docket 7. See also Aduit Corrections Offender Locator, $.D. Dep’t of Corrs., https: / /docadultlookup.sd.gov/adult/lookup/ details /Pid=mMsj9rB9RVO= (last visited June 16, 2026).

Dep't of Corr. State Jail Div., 117 F.3d 240, 241-42 (5th Cir. 1997); Robbins v. Switzer, 104 F.3d 895, 897-99 (7th Cir, 1997); In re Smith, 114 F.3d 1247, 1251 (D.C. Cir. 1997). The Eighth Circuit has not expressly weighed in on this issue but the court’s holding in Tyler is instructive. See In re Tyler, 110 F.3d 528, 529-30 (8th Cir. 1997). There, the Eighth Circuit denied the plaintiff's motion to proceed in forma pauperis and refused to address the merits of the plaintiff’s mandamus petition until the requisite financial obligations were met. Id. at 929-30. The Eighth Circuit explained that because the plaintiff had previously filed three actions dismissed as frivolous or for failure to state a claim, he was no longer eligible for a § 1915(b) installment plan. Id. at 529; see also 28 U.S.C. § 1915(g) (stating that a prisoner is not eligible for a reduced filing fee or an installment payment plan “if the prisoner has, on 3 or more prior occasions... brought an action . .. that was dismissed on the grounds that it is frivolous, malicious, or fails to state a claim”), As such, the Eighth Circuit ordered the plaintiff to pay the filing fee in full, noting that “[e]ven if [plaintiff]’s petition is dismissed, [plaintiff] will still be assessed the full filing fee because the PLRA makes prisoners responsible for their filing fees the moment the prisoner brings a civil action or files an appeal.” Tyler, 110 F.3d at 529-30. Based on this language, courts within the Eighth Circuit have held that if a prisoner filed the action while in custody, he remains liable for the filing fee even if he is later released from custody. See Domino, 2021 WL 1221188, at *1 n.3 (stating that the “holding in Tyler that the fee obligation imposed by

§ 1915(b)(1) is triggered at the time the action is filed . . . is consistent with the conclusion that a complainant who filed an action when he was a prisoner remains liable for the filing fee if he is subsequently released from custody’); Counts v. Missouri, No. 4:24-CV-01437-MTS, 2025 WL 812276, at *3 (E.D. Mo. Mar. 13, 2025) (stating that, in light of the Eighth Circuit’s decision in Tyler, the § 1983 plaintiff was “responsible for the entire [filing] fee because the full fee was assessed against him prior to his release from custody”); McFee v. Minnesota, No. 11-3614, 2012 WL 514708, at *3 nn.5-6 (D. Minn, Jan, 24, 2012) (recognizing that the plaintiff must pay the filing fee, despite having been - released from custody before the court ruled on the motion for IFP), report and recommendation adopted by 2012 WL 512611 (D. Minn. Feb. 15, 2012); Williams v. Doe #1, No. 4:06CV1344, 2006 WL 3804027, at *1 n.1 (E.D. Mo. Nov. 7, 2006) (noting “§ 1915(b)(1) continue[d] to apply” despite litigant’s release). But see Clark v. Wood, No. 4:20-CV-1215-JAR, 2021 WL 1873561, at (E.D. Mo. May 10, 2021) (stating that if a plaintiff was released from custody before the court ruled on the IFP motion, the court will consider the motion under the non-prisoner standard in 28 U.S.C. § 1915(a)(1)). The Eighth Circuit’s holding in Tyler points to requiring Winfrey to pay the full filing fee. After all, Winfrey was an inmate when he filed this action, though he has been released from custody subsequently. See 28 U.S.C. § 1915(b)(1). This application of the PLRA is consistent with other cases in the District of South Dakota. See Hilston v. Lincoln Cnty. Cir. Judges, 782 F. Supp.

3d 712, 715-717 (D.S.D. 2025); Bell v. Bittinger, No. 4:24-CV-04152-LLP, 2025 WL 1424903, at *1—-2 (D.3.D, May 16, 2025). Under the PLRA, however, the Court may accept partial payment of the initial filing fee where appropriate. Thus, “[w]hen an inmate seeks pauper status, the only issue is whether the inmate pays the entire fee at the initiation of the proceedings or over a period of time under an installment plan.” Henderson v. Norris, 129 F.3d 481, 483 (8th Cir. 1997) (alteration in original) (quoting McGore v. Wrigglesworth, 114 F.3d 601, 604 (6th Cir, 1997)). The initial partial filing fee that accompanies an installment plan is calculated according to 28 U.S.C. § 1915

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Monterion D’Allen Winfrey v. Jake Rohwer, Housing Sergent at Jameson Prison Annex SDSP, individual and official capacities; Josi Schmidt, Leutenant — Officer in Command at Jameson Prison Annex SDSP, individual and official capacities; Tabitha Benting, Warden at Jameson Prison SDSP, individual and official capacities; and Tyran Wollman Housing SGT at Jameson Prison Annex, individual and official capacities, Counsel Stack Legal Research, https://law.counselstack.com/opinion/monterion-dallen-winfrey-v-jake-rohwer-housing-sergent-at-jameson-prison-sdd-2026.