James Earl Roberts, who was proceeding without counsel, sought an out-of-time appeal from convictions for child-molestation offenses and filed an affidavit stating that he could not pay court costs. The trial court treated the affidavit as a motion to proceed in forma pauperis and denied it without a hearing. The Georgia Court of Appeals held that the procedure used to decide indigence was reviewable even though the merits of an indigence determination ordinarily are not. Under Georgia’s pauper-status statute, a hearing was required before denying Roberts’s sworn affidavit, particularly because the State had not filed a traverse contesting it. The court also held that the Prison Litigation Reform Act provision cited by the trial court applied to civil proceedings and did not govern an appeal from a criminal case. It reversed and remanded with instructions either to grant pauper status or conduct the required evidentiary hearing before reaching Roberts’s motion for an out-of-time appeal.