Skip navigation
Prison Legal News
× You've used up your 3 free articles for this month. Subscribe today.

Sixth Circuit Clarifies What Constitutes PLRA “Strike” and Reinstates Michigan Prisoner’s Lawsuit

Loaded on Nov. 1, 2025 by Matthew Clarke published in Prison Legal News November, 2025, page 18
Filed under: Filing Fees (PLRA), Frivolous Litigation, Sovereign Immunity, Access To Courts. Location: Michigan.

by Matt Clarke

On July 25, 2025, the United States Court of Appeals for the Sixth Circuit clarified what constitutes a “strike” for purposes of the Prison Litigation Reform Act’s (PLRA) “three-strikes” rule, 28 U.S.C. § 1915(g). See: Simmons v. Washington, 996 F.3d 350(6th Cir. 2021). …

 

Full article and associated cases available to subscribers.

As a digital subscriber to Prison Legal News, you can access full text and downloads for this and other premium content.

Subscribe today

Already a subscriber? Login

More from this issue:

  1. America’s Deadliest Jails: Tarrant County Edition, by Anthony Accurso
  2. Washington Prisoners Gain Access to Crisis Hotline
  3. From the Editor, by Paul Wright
  4. HRDC’s Washington Jail Debit-Release Card Suit Survives Summary Judgment, by Chuck Sharman
  5. $11 Million Paid to Estate of Mentally Ill Illinois Jail Detainee Who Lost 60 Pounds During 85-Day Incarceration, by Chuck Sharman
  6. Dying Mississippi Prisoner Wins Preservation Testimony in Suit Blaming Terminal Cancer on Exposure to Janitorial Chemicals, by Chuck Sharman
  7. Missouri Blocks Spiritual Advisors from Prison Pastor’s Execution, by Jo Ellen Nott
  8. Ninth Circuit Finds No Bivens Extension Needed for Federal Prisoner Prescribed Water and Exercise for Thyroid Storms, by Chuck Sharman
  9. Trans Kentucky Prisoner Loses Bid to Block State’s New Ban on Hormone Replacement Therapy, by Chuck Sharman
  10. Enormous $14 Million Settlement Reached by Los Angeles County with Former Prisoner Exonerated After 20 Years, by Chuck Sharman
  11. San Diego County Files Unusual Suit Against NaphCare Over Jail Detainee’s Murder, by Chuck Sharman
  12. For Delay in Summoning Medical Care for Detainees, Alabama Jailers Granted Immunity But California Trooper Headed to Trial, by Chuck Sharman
  13. Seventh Circuit Rules Against Prisoner’s Deliberate Indifference Claim Over Wexford Health’s Poor Psychiatric Care, by Michael Thompson
  14. Sixth Circuit Clarifies What Constitutes PLRA “Strike” and Reinstates Michigan Prisoner’s Lawsuit, by Matthew Clarke
  15. $2.4 Million Paid to Indiana Prisoners Sickened With Legionnaire’s Disease by Contaminated Water, by Chuck Sharman
  16. Body-Worn Camera Program for Guards Expands to all Maryland Prisons, by Chuck Sharman
  17. CoreCivic Pays $82,500 for First COVID-19 Death at San Diego ICE Lockup, by Chuck Sharman
  18. Wisconsin DOC Ordered to Provide Programming for Pregnant Prisoners—34 Years After Law Was Passed, by Chuck Sharman
  19. Securus Loses Bid to Dismiss HRDC Price-Fixing Suit, by Chuck Sharman
  20. $150,000 Paid by Jacksonville for Mother of Five’s Jail Suicide, by Chuck Sharman
  21. Federal Injunction Bars ICE from Crowding Detainees in Unsanitary “Hold” Rooms in New York City Office, by Chuck Sharman
  22. While Mentally Ill Rikers Island Detainee Lay Dying, Staff Sprayed Air Freshener, Fudged Cell Checks, by Chuck Sharman
  23. SCOTUS Overturns Oklahoma Prisoner’s Death Sentence After More than 25 Years on Death Row, by Douglas Ankney
  24. $1.8 Million Settlement Reached Following CDCR Data Breach, by Chuck Sharman
  25. North Carolina Prison Officials Run Out the Clock On Trans Prisoner’s Vulvoplasty, by Chuck Sharman
  26. Seventh Circuit Dismisses Jail Detainee Suicide Case for Lack of Showing Deliberate Indifference, by Anthony Accurso
  27. Fourth Circuit Rules in Favor of Prisoner’s Eligibility for Time Credits, by Douglas Ankney
  28. Jailhouse Lawyer Gets 16-1/2-Year Sentence for Defrauding Prisoner “Clients”, by Chuck Sharman
  29. Federal Government, CoreCivic Slow-Walk Class-Action Challenges to Forced Labor of ICE Detainees, by Chuck Sharman
  30. Oklahoma County Jailers Lose Bids to Derail Three Suits Over Detainee Murders, by Chuck Sharman
  31. Ohio Appoints Special Prosecutor to Investigate Double Amputee’s Restraint and Death
  32. Fifth Circuit Remands Louisiana Detainee’s Medical Grievance Case, by Michael Thompson
  33. South Dakota Approves $650 Million New Prison Construction
  34. Eighth Circuit Orders Preliminary Injunction Requiring Minnesota to Reinstate Program Teaching Biblical “Authentic Manhood”, by Matthew Clarke
  35. Appeals Court Rules Michigan’s Tolling Provision Is Not Inconsistent with the PLRA, by Douglas Ankney
  36. California’s Attorney General Is Suing Los Angeles County Jails Over “Inhumane Conditions”, by Michael Thompson
  37. FCC Issues Proposed Rule Permitting Cellphone Jammers in Prisons and Jails, by Chuck Sharman
  38. Preliminary Injunction Halts Solitary Confinement of Mentally Ill Prisoners at New York Lockup Where Wildcat Guard Strike Began, by Chuck Sharman
  39. Florida Sheriff Fires Five Guards for Two Cases of Detainee Abuse
  40. $5.5 Million Paid for Two Withdrawal Deaths at Washington Jail, by Chuck Sharman
  41. $950,000 Awarded to Trans Maryland Prisoner Dropped on Her Face by Guards, by Douglas Ankney
  42. Seventh Circuit Affirms Liberty Interest in Harsh Solitary Confinement Case, by Michael Thompson
  43. Eleventh Circuit Overturns 1990 Alabama Death Sentence Over Racially Biased Jury Selection; ACLU Report Shows It Is Still Happening, by Matthew Clarke
  44. Eleventh Circuit Declines to Extend to Summary Judgment Proceedings a Rule Requiring District Courts to Notify Pro Se Litigants, by Douglas Ankney
  45. BOP Cancels Union Rights for Prison Guards
  46. $4 Million Verdict Returned in Colorado Jail Suicide Case, by Chuck Sharman
  47. $100,000 Settlement Reached Between Imprisoned BOP Guard and Prisoners He Raped, by Chuck Sharman
  48. Fifth Circuit Dismisses Sex Abuse Claims Filed by Three Texas Prisoners Against Guard, by Chuck Sharman
  49. Nearly $528,000 Paid by Kansas Jail to Detainees Raped by Guards, by Chuck Sharman
  50. Two Re-Entry Non-Profit Leaders in Tennessee and Massachusetts Accused of Criminal Charges
  51. New York Jury Convicts Former Guard for Robert Brooks’ Taped Killing
  52. The Last Escaped Detainee from the New Orleans Jail Was Arrested in an Atlanta Crawlspace
  53. California Approves Higher Wage for Prisoner Firefighters (But Still Underpays)
  54. Former Prisoners’ Challenge to Virginia Constitution’s Felony Disenfranchisement Clause Allowed to Proceed, by Douglas Ankney
  55. $3.6 Million Paid by Minnesota County After Hemophiliac Jail Detainee Died from Brain Bleed, by Chuck Sharman
  56. Appeals Court Allows Illinois Prisoner’s Suit for Failure to Exhaust Administrative Remedies, by Douglas Ankney
  57. FCC Votes For Dramatic Hike to Prison Phone Call Rates, by Chuck Sharman
  58. News in Brief

More from Matthew Clarke:

More from these topics: