Jones v. Cuomo, No. 20-2174 (2nd Cir. 2021)
Nature of Case: Appellant brought a federal civil rights lawsuit challenging various aspects of his civil commitment. He moved to proceed in forma pauperis, and subsequently the 2nd Circuit deducted the filing fees from his institutional account at the civil commitment facility pursuant to the Prison Litigation Reform Act (PLRA). He subsequently moved for restoration of fees, contending that as a civil committee he was not subject to the PLRA.
Holding: The Second Circuit Court of Appeals granted the motion for restoration of fees, finding that the Appellant did not qualify as a “prisoner” under the PLRA and thus it was error to deduct the filing fees from his institutional account.