Caseflicks

Supreme Court of the United States • 1992

Rowland v. California Men's Colony, Unit II Men's Advisory Council

503 U.S. 1003

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Takeaway

In short, this case holds that the federal in forma pauperis statute protects indigent human litigants, not organizations that seek to litigate without paying court fees.

Background

The California Men's Colony, Unit II Men's Advisory Council (MAC), an unincorporated association of prison inmates, sued California prison officials in federal court. MAC sought permission to litigate in forma pauperis under 28 U.S.C. § 1915, which permits qualifying litigants to proceed without prepaying court fees and costs.

The District Court denied MAC's request on the ground that an unincorporated association was not a “person” eligible for in forma pauperis status under § 1915. The Ninth Circuit reversed, concluding that the statute allowed an association to proceed without prepayment of fees. The Supreme Court granted review and reversed the Ninth Circuit.

Issues

Issue #1

Whether an unincorporated association or other artificial entity is a “person” that may proceed in forma pauperis under 28 U.S.C. § 1915.

Holding

No. Section 1915 permits only natural persons, not artificial entities such as unincorporated associations, to proceed in forma pauperis.

Reasoning

Although the federal Dictionary Act ordinarily defines “person” broadly enough to include associations and corporations, that definition applies only when the statutory context does not indicate a different meaning. The context of § 1915 indicates that Congress used “person” to mean a natural human being.

Section 1915 requires an affidavit stating that the affiant cannot pay the costs of litigation and believes that he is entitled to relief. Those requirements reflect the statute's focus on an individual's personal poverty and sworn assessment of a claim, rather than on the financial position of an organization.

The statute's history confirmed that reading. The original federal in forma pauperis law was designed to give impoverished individual litigants access to federal court. Congress later replaced the word “citizen” with “person” principally to extend that opportunity to indigent noncitizens, not to expand the statute to corporations, partnerships, or associations.

The Court also found that the statute's purpose supported this interpretation. An artificial entity can aggregate resources from its members, owners, or affiliates, while a natural person may lack any comparable source of support. Congress did not clearly create an exemption from filing fees for entities merely because the entity itself lacks available funds.

Concurrences

Justice Thomas

Reasoning

Justice Thomas, joined by Justice Scalia, agreed that MAC could not proceed in forma pauperis. He wrote separately because he would rest the result on the statutory text and its affidavit-based procedure, without relying on the legislative history discussed by the Court.

In his view, § 1915's requirement that the litigant personally make a sworn showing of inability to pay and belief in the claim identifies the intended beneficiary as a natural person. That textual context was sufficient to displace any broader default definition of “person.”