Wilkinson Stekloff achieved another important pro bono victory in the U.S. Court of Appeals for the Eleventh Circuit, securing reversal of a district court’s dismissal of an incarcerated individual’s civil rights complaint under the Prison Litigation Reform Act’s (“PLRA”) three-strikes rule.
The appeal was led by associates Logan Page and Daniel Cook. The case arose after a Georgia district court denied our client the ability to proceed in forma pauperis and dismissed his complaint for non-payment of the filing fee, concluding that four prior lawsuits constituted “strikes” under the PLRA. Through briefing, Logan and Daniel demonstrated that at least two of those dismissals could not be considered strikes. The Eleventh Circuit agreed, reversing the district court’s judgment and remanding for further proceedings.
This result builds on Logan’s prior appellate success before the Sixth Circuit in 2024, where the court unanimously vacated a similar PLRA dismissal following his oral argument. Logan first identified courts’ misapplication of the PLRA while clerking and has since made it a focus of his pro bono practice, seeking opportunities to challenge improper enforcement of the statute. Reflecting his dedication, Logan was named to the DC Pro Bono Honor Roll in 2023 and 2024, earning High Honors distinction both years since joining the firm.
Wilkinson Stekloff also previously secured similar relief from the Second Circuit, overturning a district court judge’s decision barring our client from filing further complaints while incarcerated. These victories underscore Wilkinson Stekloff’s commitment to ensuring that individuals in any circumstance can obtain meaningful access to justice, even when facing procedural barriers.
Since its founding in 2016, Wilkinson Stekloff has handled more than 100 pro bono matters, with attorneys across the firm dedicating thousands of hours to cases involving civil rights, family law, immigration, and post-conviction representation. The firm has been recognized by Chambers and Partners, Law360 Pulse, and the Capital Pro Bono Honor Roll, among others, for making this work a central element of firm life.