In Jae v. Good, 946 A.2d 802 (Pa. Cmwlth.), petition for allowance of appeal denied, 598 Pa. 790, 959 A.2d 930 (2008), the Court resolved the issue of whether the Act applied when a prisoner sought to have Pennsylvania courts enforce his rights under Section 1983. The Court determined: Our state courts must apply federal law to evaluate the substantive merits of . . . a First Amendment Claim. . . . However, our courts must also follow the rules of procedure that govern any civil litigation brought in our court system. . . . Thus, federal law governs the substantive merits of a Section 1983 action brought in state court, but state law governs the procedures by which that action will be litigated. Section 6602(f) of the PLRA does not establish substantive law but is entirely procedural because it relates to payment of court filing fees. . . . Because Jae John Richard Jae, a prisoner brought his civil action in state court and sought relief from filing fees by requesting permission to proceed in forma pauperis, the Pennsylvania PLRA, not the federal analog, applied to Jae's action, as the trial court correctly held. Jae, 946 A.2d at 809-810. The Court stated that the "three strikes rule" of Section 6602(f) of the PLRA does not prevent prisoners from filing any number of civil actions challenging prison conditions. It only restricts their ability to pursue such actions in forma pauperis. There is a legitimate governmental interest in deterring frivolous law suits, and Section 6602(f) advances that goal rationally by depriving an abusive litigator of the ability to proceed in forma pauperis. Further, the legislation balances the need to deter prisoners from filing frivolous litigation against the need to protect prisoners from physical harm.