Wilson v. Ramsey County ADC Jail

Background

Edward Wilson filed two complaints against Ramsey County and related defendants alleging medical mistreatment while incarcerated. The court consolidated the actions and previously dismissed the complaints under 28 U.S.C. § 1915A after finding that Wilson had not pleaded sufficient facts. The court gave him an opportunity to file an amended complaint if he believed he could state a claim for relief. Wilson did not use that opportunity. Instead, he filed notices of appeal and applications to proceed in forma pauperis, meaning to appeal without paying the filing fee.

Legal standard

Under 28 U.S.C. § 1915, a person seeking to appeal without paying the filing fee must show that they cannot afford the fee. Even if the person is unable to pay, the court must deny that status if the appeal is not taken in good faith. The court evaluates good faith objectively by asking whether the appeal is frivolous—that is, whether it lacks an arguable basis in law or fact.

Ruling

The court stated that Wilson’s bare-bones complaints did not state claims for which federal law provides relief and did not establish federal subject-matter jurisdiction over possible state-law claims. Because Wilson had not amended the complaints and the claims had no arguable basis in law, the court found that his appeals were frivolous. Judge John R. Tunheim therefore denied Wilson’s applications to proceed in forma pauperis on appeal in both civil cases.

Disposition

The applications to proceed in forma pauperis on appeal were DENIED.