The Sixth Circuit Court of Appeals ruled on November 10, 2026, that Tyrelle Motray Henderson, Jr., a Michigan state prisoner, can proceed with his lawsuit against Kent County, Michigan. The court found that the lower court incorrectly classified Henderson's previous lawsuits as strikes under the Prison Litigation Reform Act (PLRA), which would have prevented him from filing this case without paying the required fees.

This ruling is significant for Henderson, who has faced multiple legal challenges while incarcerated. The decision allows him to continue seeking justice in his claims against the county and its sheriff, Michelle Lajoye-Young, without the financial burden that could have barred him from pursuing his case.

Background

Tyrelle Henderson filed a lawsuit against Kent County and Sheriff Michelle Lajoye-Young, claiming violations of his constitutional rights. When he sought to proceed in forma pauperis (IFP), which allows individuals to file lawsuits without paying fees upfront, the district court denied his request. The court ruled that Henderson had accumulated three strikes under 28 U.S.C. § 1915(g), which would prevent him from proceeding IFP unless he could demonstrate imminent danger of serious physical injury.

Henderson challenged this ruling, arguing that two of the actions cited by the district court as strikes were dismissed on Eleventh Amendment immunity grounds. He contended that these dismissals should not count as strikes under the PLRA. The defendants, Kent County, argued that issue preclusion barred Henderson from contesting the strikes and asserted that he had at least three strikes based on his previous lawsuits.

The Ruling

The Sixth Circuit Court of Appeals, with Judges Richard Allen Griffin, John K. Bush, and John B. Nalbandian presiding, ruled in favor of Henderson. The court found that the district court's classification of Henderson's previous lawsuits as strikes was incorrect. The opinion stated, "a dismissal premised on Eleventh Amendment immunity does not appear on the list of [§ 1915(g)’s] grounds for a cognizable strike." This means that dismissals based on this immunity do not count against a prisoner’s ability to proceed IFP.

Further, the court noted that the district court had erroneously concluded that Henderson had three strikes. The ruling clarified that Henderson had only one strike based on the actions identified by the district court. The court vacated the lower court's decision and remanded the case for further proceedings, allowing Henderson to proceed with his lawsuit.

Impact

This ruling has significant implications for Henderson and potentially for other prisoners seeking to file lawsuits. By clarifying that dismissals based on Eleventh Amendment immunity do not count as strikes, the court has opened the door for Henderson to pursue his claims without the financial burden of filing fees. This decision may also influence how courts handle similar cases in the future, potentially leading to more prisoners being allowed to proceed IFP.

The ruling emphasizes the importance of accurately classifying previous lawsuits when determining a prisoner's ability to file new actions. It highlights the need for courts to carefully consider the grounds for dismissals to avoid unjustly preventing individuals from seeking legal recourse.

What's Next

Following this ruling, Henderson can now proceed with his lawsuit against Kent County. The case will return to the district court for further proceedings. There is no indication in the court filing that this decision will be appealed, but future related cases may arise as other prisoners challenge their strike classifications.