## Facts

- A prison inmates’ advisory council, formed to communicate inmate complaints and recommendations to prison officials, filed a federal civil rights suit against state correctional officials.
- The suit alleged that ending free tobacco for indigent inmates violated the Eighth and Fourteenth Amendments.
- The council sought to proceed in forma pauperis (IFP) under 28 U.S.C. § 1915(a), supported by an affidavit asserting the council was indigent and could not hold funds under prison rules.
- The district court denied IFP for inadequate proof of indigency, indicating it would consider a renewed application with financial details for each individual inmate.
- The court of appeals held the council could qualify as a “person” under § 1915(a), relying on the Dictionary Act’s definition of “person” as including associations.
- The Supreme Court granted review.

## Issues

1. Whether an association or other artificial entity is a “person” eligible to proceed in forma pauperis under 28 U.S.C. § 1915(a).
2. Whether the Dictionary Act’s inclusion of “associations” within “person” applies to § 1915(a), or whether statutory context limits “person” to natural persons.

## Decision

- The Supreme Court reversed the court of appeals in a 5–4 decision.
- The Court held that “person” in 28 U.S.C. § 1915(a) refers only to natural persons, not associations or other artificial entities.
- The Dictionary Act did not control because the context of § 1915 indicates a narrower meaning.
- The council, as an entity, could not receive IFP status, even if its individual members might be indigent.

## Legal Principles

- Under 1 U.S.C. § 1, Dictionary Act definitions apply unless statutory context indicates otherwise; “context” is derived principally from statutory text and related statutes.
- The text and structure of § 1915 indicate Congress contemplated human litigants, including:
  - the statute’s assumption that the eligible “person” may proceed without counsel and seek court-requested counsel, while artificial entities generally cannot appear pro se in federal court;
  - the statute’s use of “poverty,” a condition associated with natural persons;
  - the statute’s design presupposing personal financial disclosure and responsibility consistent with individual affiants.
- Consequently, artificial entities (including associations) are not eligible to proceed IFP under § 1915(a), though individual members may seek IFP in their own names if otherwise qualified.

## Conclusion

The Court limited in forma pauperis status under 28 U.S.C. § 1915(a) to natural persons, holding that statutory context overrides the Dictionary Act’s broader definition and bars associations, including inmate councils, from obtaining IFP status as entities.


Rowland v. Cal. Men’s Colony, Unit II Men’s Advisory Council, 506 U.S. 194 (1993)