James Rowland, Former Director, California Department of Corrections, et al. v. California Men's Colony, Unit II Men's Advisory Council
The court held that only a natural person may qualify for in forma pauperis (IFP) treatment in federal court under 28 U.S.C. § 1915, and that the term "person" as used in § 1915 does not include artificial entities.
506 U.S. 194 · No. 91-1188 · 1992 term · Rehnquist Court
Decided Jan 12, 1993 · argued Oct 6, 1992
Civil rights · Indigents: miscellaneous
Majority opinion: David Souter
The voteMajorityDissent
5–45 in the majority, 4 in dissent
4 dissents (5–4)
Reversed and remanded. James Rowland, Former Director, California Department of Corrections, et al. won.
What this ruling means
Reversed and remanded: the Supreme Court overturned the decision of the U.S. Court of Appeals, Ninth Circuit and sent the case back to that court for further proceedings that follow the Supreme Court’s ruling.
James Rowland, Former Director, California Department of Corrections, et al. was the petitioner, the side that asked the Supreme Court to review the case. “Won” means the Court gave that side the result it asked for.
From the Supreme Court Database. A justice who agreed with the result but not the reasoning counts in the majority.
Summary
The opening of the case’s Wikipedia article: what the case was about and what the Court held.
Rowland v. California Men's Colony, Unit II Men's Advisory Council, 506 U.S. 194 (1993), was a United States Supreme Court case in which the court held that only a natural person may qualify for in forma pauperis (IFP) treatment in federal court under 28 U.S.C. § 1915, and that the term "person" as used in § 1915 does not include artificial entities.
Data notes
The text is Wikipedia’s (CC BY-SA 4.0), matched to the case by its citation, docket number or name and year, and is not checked against the opinion. The site keeps the article’s opening section, ending on its last full sentence. The one-sentence summary under the title is the Decisions list’s: Wikipedia’s own ruling sentence, or, tagged “AI-written”, one Claude wrote from this opening.
How the justices voted
Each justice who took part, placed by their Martin–Quinn ideology score for the 1992 term. Filled: the 5 in the majority. Hollow: the 4 in dissent. Colour is the party of the president who appointed them.
Majority(5)
David SouterWrote the majority opinion
Byron WhiteJoined the majority
Sandra O'ConnorJoined the majority
William RehnquistJoined the majority
Antonin ScaliaJoined the majority
Dissent(4)
Anthony KennedyWrote a dissent
Clarence ThomasWrote a dissent
John StevensJoined a dissent
Harry BlackmunJoined a dissent
Data notes
Each justice’s vote and what they wrote are from the justice-centered file of the Supreme Court Database. “Wrote a concurrence” means the justice sided with the majority and wrote separately; a justice who dissented in part is counted on the side they took overall. A justice who wrote nothing is listed as joining their side.
Positions are each justice’s Martin–Quinn score for the case’s term, the same scores as the Ideology page: negative is more liberal, positive more conservative. A score sums up a justice’s votes across the whole term, so it says where they usually sit, not why they voted as they did here. The median line is the Court’s median justice that term.
The parties
Who brought the case to the Court, who answered it, and how it got there.
- Petitioner
- James Rowland, Former Director, California Department of Corrections, et al.Governmental official, or an official of an agency established under an interstate compact (California)
- Respondent
- California Men's Colony, Unit II Men's Advisory CouncilPrisoner, inmate of penal institution
- Reached the Court by
- Certiorari (the Court chose to hear it)
- Why it was taken
- Federal appeals courts had ruled differently on the question
Data notes
The names are the two sides of the case’s title. The description under each is the Supreme Court Database’s category for that party, in its own wording. The petitioner is the side that asked the Supreme Court to review the decision below. “Why it was taken” appears only when the majority opinion says lower courts disagreed or were unsure about the question; reasons that would fit any case (“to resolve the question presented”, “an important question”) are left out.
The law at issue
The law the Court was asked to apply, and the kind of power it used to decide.
- Provision
- 28 U.S.C. § 1915
- Kind of law
- Infrequently litigated statutes
- Decided by
- Statutory construction
Data notes
The Supreme Court Database codes the main constitutional provision, statute or court rule each case turned on, and the basis of the decision: judicial review of a federal or state law, interpreting a statute, supervising the lower courts, and so on. A case can rest on more than one. “Overruled” counts only where the majority opinion says so.
Timeline
What happened at the Court and how the case got there, newest first.
- Jan 12, 1993DecidedDecided · Decided 5–4: reversed and remanded. James Rowland, Former Director, California Department of Corrections, et al. won.
- Oct 6, 1992ArguedArgued · Oral argument before the Court.
- Not datedTaken upTaken up · The Supreme Court agreed to hear the case (certiorari). Federal appeals courts had ruled differently on the question.
- Not datedCourt belowCourt below · Decided by the U.S. Court of Appeals, Ninth Circuit: reversed and remanded.
- Not datedBeganBegan · The case began in the California Central U.S. District Court.
Data notes
From the Supreme Court Database: the court the case began in, the court whose decision the Supreme Court reviewed and what that court did, how the case came to the Court, and the dates of argument and decision. The database does not date the steps in the lower courts. Court names are the database’s.
Other decisions on the same issue
5 other argued cases since 1946 on indigents: miscellaneous, newest first.
- Ayestas v. Davis138 S. Ct. 1080Mar 21, 2018 · 138 S. Ct. 1080Civil rights9–0Unanimous band
- Neitzke et al. v. Williams490 U.S. 319May 1, 1989 · 490 U.S. 319Civil rights9–0Unanimous band
- Nowakowski v. Maroney, Correctional Superintendent386 U.S. 542Apr 10, 1967 · 386 U.S. 542Civil rights9–0Unanimous band
- Coppedge v. United States369 U.S. 438Apr 30, 1962 · 369 U.S. 438Civil rights5–27–2 band
- Roberts v. United States District Court for the Northern District of California et al.339 U.S. 844Jun 5, 1950 · 339 U.S. 844Civil rights8–18–1 band
Data notes
Every other orally argued case with a clear vote, from the 1946 term on, that the Supreme Court Database files under the same issue as this one. The database gives each case one issue from a list of about 270 (abortion, search and seizure of vehicles, the death penalty, and so on), whatever law it turned on.
Official record
Read the full opinion on Justia, the argument audio on Oyez and Wikipedia. Case data from the Supreme Court Database, Version 2026 Release 01, through the 2025 term.