Case Explained: Barnett v. Bridges, et al.

Court: United States Court of Appeals for the Tenth Circuit

Filed: 2026-07-14

Docket: 4:23-CV-00232-GKF-JFJ)

The Tenth Circuit denied Christopher Barnett’s motion for leave to proceed in forma pauperis, thereby preventing him from appealing the dismissal of his civil rights suit against prison officials without paying the filing fee. The court applied the three-strikes rule under 28 U.S.C. § 1915(g) of the Prison Litigation Reform Act (PLRA), which bars prisoners with at least three prior dismissals for frivolousness or failure to state a claim from proceeding in forma pauperis unless they demonstrate an imminent danger of serious physical injury. While Barnett did not contest his three prior dismissals, the court held that he failed to satisfy the required nexus between his alleged imminent danger and the claims in his complaint. Adopting the two-part test from the Second Circuit regarding standing, the court required a showing that the alleged injury is traceable to the defendant’s conduct and that a favorable judicial outcome would redress that injury. The court determined that the relief requested in Barnett’s complaint—addressing retaliation for complaining about a mail clerk and limited court access—would not redress his alleged danger of beatings and relocation to a more dangerous prison, particularly since he had been transferred to a different facility during litigation where the current defendants lacked control over his conditions. Consequently, the motion is denied; if Barnett does not pay the appellate filing fee within 30 days, the appeal may be dismissed for failure to prosecute.

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