Arzuaga v. Quiros, No. 13-4586 (2d Cir. 2015)
Annotate this CaseOver the past several years, Arzuaga, who is currently incarcerated in Connecticut, filed three separate actions against prison officials under 42 U.S.C. 1983. Although the district court initially granted Arzuaga’s motion to proceed in forma pauperis (IFP), the court later revoked Arzuaga’s IFP status because Arzuaga had received approximately $6,000 in past‐due Social Security benefits that he had not reported to the court. Arzuaga subsequently failed to pay the filing fees. The district court dismissed all three actions. The Second Circuit vacated. Arzuaga’s past‐due Social Security benefits did not provide a basis for revoking his IFP status because the No Social Security Benefits for Prisoners Act of 2009 barred Arzuaga from accessing those benefits while incarcerated, 42 U.S.C. 404(a)(1)(B)(ii). After the three complaints were filed, Arzuaga received a separate deposit of $350 into his prisoner trust account and spent that money on consumer goods rather than filing fees. The court rejected an argument that by failing to apply these funds to filing fees, Arzuaga made himself ineligible for IFP status.
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