Jimenez v. Medical Health Services
- Susan Illston
- 3:09-cv-02328
- U.S. District Court · Northern District of California
- 3
In Jimenez v. Rowe, Judge Illston denied relief from prison filing-fee deductions, ruling that multiple fees may be collected simultaneously.
Robert C. Jimenez, whose inmate-account deductions for filing fees were upheld; the order also describes how prison officials may collect fees from prisoners who owe fees in multiple cases.
What happened
In Robert C. Jimenez v. Rowe, et al., Robert C. Jimenez complained that prison officials were taking too much money from his inmate account to pay filing fees. The court said his letter was unclear but addressed his possible objections, including the amount deducted, multiple fees, simultaneous deductions, and money for personal expenses.
The court explained that prisoners allowed to proceed without paying the full filing fee upfront must repay the fee in monthly installments. When a prisoner owes fees in multiple cases or appeals, officials may collect payments for all of them at the same time. The court also said there is no requirement that Jimenez be allowed to keep 55% of his account balance or reserve money for incidental expenses.
The court provided no relief from Jimenez’s filing-fee obligations and ordered the case accordingly. Judge Susan Illston explained that, if a prisoner owes five or more filing fees, deductions can take all money entering the account, as authorized by federal law.
The detailed version
- Jimenez v. Medical Health Services · No. 3:09-cv-02328
- Susan Illston
- Jan. 21, 2021
Background
The court received a letter from Robert C. Jimenez complaining about filing-fee deductions in this long-closed case. The court said the exact issue was unclear. The letter appeared to argue that prison officials could take only 55% of the balance in his inmate account, that he should not owe multiple filing fees, that multiple fees should not be collected at once, and that he should be allowed to keep money for incidental expenses.
Legal framework
The court explained that a prisoner allowed to proceed without prepaying the full filing fee must still pay the full fee as money enters the prisoner's inmate trust account. Under 28 U.S.C. § 1915(b), after an initial partial payment, the prisoner generally pays monthly installments based on income credited to the account. The agency holding the account forwards payments when the account balance exceeds $10, until the fee is paid.
The court also relied on the Supreme Court's decision that when a prisoner owes filing fees in multiple cases, the fees are collected simultaneously rather than one after another. Jimenez owed multiple fees because he had filed several cases and appeals in which he had been allowed to proceed without paying the full filing fee upfront.
Court's ruling
The court concluded that Jimenez was not entitled to relief under any reasonable interpretation of his letter. It held that no rule required prison officials to let him keep 55% of his account balance, wait until one fee was fully paid before collecting other fees, or reserve money for incidental expenses. If a prisoner has five or more outstanding filing fees, the court stated, officials may take all money entering the account to satisfy those obligations. The court provided no relief from Jimenez's filing-fee obligations and ordered: “IT IS SO ORDERED.” Judge Susan Illston signed the order on January 21, 2021.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.