In Payne v. Commonwealth Dep't of Corr., 813 A.2d 918, 928 (Pa. Cmwlth. 2002), affirmed in part and reversed in part, 582 Pa. 375, 871 A.2d 795 (2005), this Court determined that the "three strikes provision" contained in Section 6602(f)(1) of the Prison Litigation Reform Act (PLRA) was analogous to a jurisdictional hurdle that one seeking in forma pauperis status to challenge prison conditions must overcome. Section 6601 of the PLRA, 42 Pa.C.S. 6601, defines prison conditions litigation as: A civil proceeding arising in whole or in part under Federal or State law with respect to the conditions of confinement or the effects of actions by a government party on the life of an individual confined in prison. The term includes an appeal. the term does not include criminal proceedings or habeas corpus proceedings challenging the fact or duration of confinement in prison.