Tennessee Prisoner in Private Prison Not "Inmate" by Statutory Definition

The Tennessee Court of Appeals held that because a state prisoner housed
at a privately operated prison was not an "inmate" within the statutory
definition, he was not required to comply with certain standards governing
prisoner-initiated lawsuits.

James P. Block, a Tennessee prisoner at the Corrections Corporation of
America (CCA)-operated Whiteville Correctional Facility (WCF), was injured
when he slipped and fell on a wet floor. Block subsequently sued CCA and
officials at WCF alleging negligence. Block also filed a Uniform Civil
Affidavit of Indigence and was granted pauper status.

The defendants moved for dismissal, contending that Block had not complied
with Tennessee Code Annotated (TCA) sections 41-21-805 and 41-21-806. TCA
41-21-805 requires a prisoner requesting indigent status to file an
affidavit detailing all previous litigation. TCA 41-21-806 requires a
prisoner to exhaust the grievance process before filing a claim. The trial
court granted the defendants' motion and dismissed the claim. Block
appealed.

On April 30, 2001, the Tennessee Court of Appeals at Jackson reversed and
remanded, holding that Block was not an "inmate" as defined in the
relevant statutes. The Tennessee General Assembly, the appellate court
held, "has specifically defined 'inmate' as 'a person housed in a facility
operated by the department or housed in a county jail.'" TCA § 41-21-801(4)
(1997). "'Department' is defined as the Department of Correction." TCA §
41-21-801(3)(1997). Consequently, because Block was not an "inmate" by the
statutory definition, dismissal for failure to comply with TCA 41-21-805
and 41-21-806 was improper. This case was not published in S.W.3d. See:
Block v. Crants, Case No. W2000-01917-COA-R3-CV (Tenn. Ct. App. 2001).

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