Wallace v. Baldwin

Citation: 895 F.3d 481Docket: No. 17-2427

Court: Court of Appeals for the Seventh Circuit; July 9, 2018; Federal Appellate Court

SummaryOriginalCytator Case TreatmentBackward CitatorAnalysis

EnglishEspañolSimplified EnglishEspañol Fácil

Maurice Wallace, convicted of murder and sentenced to life without parole in 2006, has been in solitary confinement for over eleven years following an assault on a guard. He suffers from severe mental illness, which he claims has worsened due to prolonged isolation, leading to heightened suicide risk and potential violations of his Eighth and Fourteenth Amendment rights. Wallace filed a complaint against prison officials and the Illinois Department of Corrections, seeking to proceed in forma pauperis due to his inability to pay the civil filing fee. The district court denied his request, citing three "strikes" under the Prison Litigation Reform Act (PLRA) for frivolous cases and determining he did not meet the exception for imminent danger of serious physical injury. On appeal, it was concluded that the district court's denial was erroneous, as Wallace sufficiently demonstrated he faced imminent danger and had not yet accrued three strikes under the PLRA. The appellate court vacated the district court's judgment and remanded for further proceedings, emphasizing a de novo review of the PLRA's three-strikes provision. Wallace's complaint details the harsh conditions of his confinement, describing the cell as small, dark, and uninhabitable, which contributes significantly to his deteriorating mental health.

Wallace, diagnosed with post-traumatic stress disorder and taking antidepressants, continues to suffer from significant mental health issues, including depression, anxiety, panic attacks, sleep disturbances, and auditory hallucinations. He claims that his prolonged segregation in prison has heightened his risk of suicide, having attempted it at least five times, with the last attempt occurring in late 2016. Despite numerous written requests to be informed about the end of his segregation, prison staff have largely ignored or denied these requests without explanation. Wallace filed a lawsuit under 42 U.S.C. § 1983 against the Department and prison officials, alleging violations of his Eighth and Fourteenth Amendment rights due to their deliberate indifference to his mental health and suicide risk. He applied to proceed in forma pauperis, citing three prior "strikes" under the PLRA for dismissed cases but argued he faced imminent danger of serious physical injury. The district court denied his application, determining his suicidal thoughts did not indicate "imminent danger." The court referenced that a prisoner cannot create such danger and ruled against Wallace's claims. Wallace appealed, continuing to seek in forma pauperis status, and the appeal court expressed disagreement with the district court's position, particularly regarding mental illness and self-harm. Wallace referenced studies linking solitary confinement to increased self-harm risk, supported by psychiatric experts indicating that such confinement can lead to severe and lasting mental health consequences, including a heightened risk of suicide.

Concurring opinions in **Davis v. Ayala** and dissent in **Glossip v. Gross** highlight the harmful mental-health effects of solitary confinement, with calls for a global ban on extended periods of such confinement. Wallace argues that prolonged solitary confinement leads to imminent self-harm risks for all prisoners, a claim that aligns with findings from the **Sanders v. Melvin** case involving a mentally ill prisoner who spent eight years in solitary and faced similar self-harm risks. The court finds Wallace's situation comparable, as he has spent eleven years in solitary, suffers from serious mental illness, and has a history of self-harm, thus establishing that he faces imminent danger of serious bodily injury.

Additionally, the court addresses a procedural issue regarding Wallace's "strikes" under § 1915(g). Only two of the three strikes against him were valid; the third was improperly assessed when a judge denied a motion to intervene in another lawsuit. The court clarifies that a motion to intervene does not constitute bringing a civil action, and therefore should not count as a strike. The court vacates the district court's denial of Wallace's motion to proceed in forma pauperis and remands for further proceedings consistent with the opinion.