Case Citator › Jennings v. Natrona County Detention Center Medical Facility

Jennings v. Natrona County Detention Center Medical Facility

Is it still good law? What later courts have actually done to this case.

Overruled in part
Court
Tenth Circuit
Citation
175 F.3d 775
Decided
Confirmed treatments
2
Flagged citations read
36 of 36
Citing cases (total)
36
Treatment dates
2002–2015
Overruled in part
A reviewed court has overruled part of this case’s holding. Jennings v. Natrona County Detention Center Medical Facility was overruled in part. The Supreme Court held in Coleman v. Tollefson that a qualifying dismissal counts as a strike in a later lawsuit even while an appeal is pending, contrary to Jennings's rule requiring exhaustion or waiver of appeal rights.
More on how this was screened

Later Tenth Circuit opinions, including Graham v. Taylor, describe Jennings as overruled on that ground. The Seventh Circuit also rejected Jennings's approach before Coleman. Both adverse treatments are listed below. All 36 flagged citations have been read; other opinions continued to apply Jennings's separate rule for frivolous appeals or reported Coleman's treatment without acting on Jennings themselves.

Every treatment on this page is written from the citing opinion itself, with a verbatim quote, never copied from a commercial citator. A citation flagged by our screen but not shown here was read and found not to weaken this case.

36 later cases cite Jennings v. Natrona County Detention Center Medical Facility; 36 of those citations sat close to treatment language and were flagged for reading, and all of them have been read. Citations that did not sit near treatment language were not flagged and were not read one by one, so a court that weakened this case without using any of that language would not appear here.

Relying on Jennings v. Natrona County Detention Center Medical Facility?

This page shows what later courts did to it. Ask about your specific facts and see whether it still carries your argument, with citations you can check.

Treatments

Overruled in part

  • The Supreme Court displaced Jennings's rule that a qualifying dismissal cannot count as a strike in a later lawsuit until appeal rights have been exhausted or waived.

    Coleman v. Tollefson · Supreme Court of the United States · filed

    We conclude that the courts must count the dismissal even though it remains pending on appeal.
    Read the full opinion on CourtListener →

Declined to follow

  • The Seventh Circuit rejected Jennings's approach to a prisoner's third strike and required the prisoner to seek leave to appeal without prepaying fees under Rule 24(a)(5).

    Ronald Robinson v. Judy Powell · Seventh Circuit · filed

    Jennings v. Natrona County Detention Center Medical Facility, 175 F.3d 775, 779-80 (10th Cir.1999). The concern expressed by those courts is legitimate, but it does not require twisting the statute and allowing a fourth strike.
    Read the full opinion on CourtListener →

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