Melvin Anderson v. R.H. Rison, Warden, Usmcfp, Springfield, Mo S.D. Paciorek G. Klingingner
Docket: 95-2479
Court: Court of Appeals for the Eighth Circuit; July 26, 1996; Federal Appellate Court
Melvin Anderson, a federal prisoner, appealed the district court's order denying him leave to proceed in forma pauperis (IFP) and dismissing his civil rights complaint under Bivens without prejudice. Anderson claimed that federal prison officials unlawfully detained him at the United States Medical Center for Federal Prisoners in Springfield, subjected him to a four-day seclusion in a stripped cell with constant lighting and surveillance, restrained him in four-point restraints, seized his blood, and force-fed him without consent, alleging these actions were punitive and intended to harm him. During an initial review under 28 U.S.C. § 1915(d), the magistrate judge ordered the defendants to explain why IFP status should be denied. The defendants submitted affidavits detailing the circumstances of Anderson’s treatment, which the district court found frivolous, leading to the denial of IFP status and dismissal of the complaint. The Eighth Circuit reversed the district court's decision, stating that it improperly considered the defendants' evidence when determining the frivolous nature of Anderson's claims. The court emphasized that the IFP status should be determined solely based on the complaint's allegations, and if the complaint is not frivolous or malicious, IFP status should be granted. The complaint did not present legally or factually baseless claims. Thus, the court concluded that the district court abused its discretion in denying IFP status and dismissing the complaint without prejudice. Anderson's motion for document production was rendered moot due to this ruling.