Willie Wright, an incarcerated pro se litigant, sued Georgia prison officials under state tort law and 42 U.S.C. § 1983 and asked to proceed without paying filing fees. The defendants argued that Wright’s prior federal lawsuits counted as strikes under Georgia’s Prison Litigation Reform Act (PLRA); the trial court agreed and dismissed his action without prejudice. The Court of Appeals held that the statute’s phrase “any action in any court of this state” refers to Georgia courts and does not include prior federal actions, so those dismissals did not bar Wright’s state-court request to proceed in forma pauperis. The court rejected the defendants’ policy argument for extending the statute beyond its text, reversed, and remanded for further proceedings. Judge McFadden concurred fully and specially, emphasizing that courts must apply statutory text while giving due consideration to legislative intent.