Barnett v. Bridges, et al.
Split Score
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Case Summary
Disposition
Dismissed
The Tenth Circuit denied Oklahoma prisoner Christopher J. Barnett’s motion to proceed in forma pauperis on appeal under 28 U.S.C. § 1915(g). Although Barnett claimed imminent danger, the court adopted the Second Circuit’s two-part nexus test (traceability and redressability) and found Barnett’s alleged danger was not redressable by the relief sought, so the fee exemption was unavailable.
Circuit Split Identified
Legal Issue
Whether a prisoner who invokes the imminent-danger exception to 28 U.S.C. § 1915(g) must show both traceability and redressability (a two-part nexus) between the alleged danger and the claims in the complaint.
Circuit Positions
Imminent-danger exception requires BOTH traceability and redressability (two-part nexus test)
Imminent-danger exception requires nexus/traceability but NOT redressability
Conflict Summary
The Second, Ninth, Federal, and now Tenth Circuits require that the alleged imminent danger be both fairly traceable to the defendants’ conduct and redressable by the requested relief, while the Fourth Circuit requires only a causal nexus (traceability) without a separate redressability showing.