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Coleman v. Kemna

Citations: 352 S.W.3d 604; 2011 Mo. App. LEXIS 1272; 2011 WL 4444069Docket: WD 72842

Court: Missouri Court of Appeals; September 27, 2011; Missouri; State Appellate Court

Narrative Opinion Summary

Lawrence Coleman appealed the trial court's judgment dismissing his petition for judicial review against Mike Kemna and others. Coleman argued three main points: 1. The trial court erred in determining that his petition did not state a claim for relief, asserting that the Missouri Department of Corrections' process for determining inmate property constitutes a contested case eligible for judicial review. 2. The trial court improperly denied his request to proceed in forma pauperis, as it mandated a payment of twenty percent of his monthly income to the court clerk until the $150 filing fee was fully paid. 3. The trial court failed to comply with the federal Prisoner Litigation Reform Act by imposing a twenty percent payment requirement despite Coleman's monthly income being less than ten dollars. The Missouri Court of Appeals, Western District, affirmed the trial court's decision. The motion for rehearing and/or transfer to the Supreme Court was denied on November 22, 2011.

Legal Issues Addressed

Compliance with the Federal Prisoner Litigation Reform Act

Application: The court upheld the trial court's imposition of a payment plan for the filing fee, despite Coleman's claim that it violated the federal Prisoner Litigation Reform Act given his low monthly income.

Reasoning: The trial court failed to comply with the federal Prisoner Litigation Reform Act by imposing a twenty percent payment requirement despite Coleman's monthly income being less than ten dollars.

In Forma Pauperis Application Requirements

Application: The trial court required Coleman to make payments toward the filing fee, despite his request to proceed in forma pauperis, which was upheld by the appellate court.

Reasoning: The trial court improperly denied his request to proceed in forma pauperis, as it mandated a payment of twenty percent of his monthly income to the court clerk until the $150 filing fee was fully paid.

Judicial Review of Inmate Property Determination

Application: The court found that the Missouri Department of Corrections' process for determining inmate property does not constitute a contested case eligible for judicial review, affirming the trial court's decision.

Reasoning: The trial court erred in determining that his petition did not state a claim for relief, asserting that the Missouri Department of Corrections' process for determining inmate property constitutes a contested case eligible for judicial review.