Jane Doe v. The Trustees of Columbia University
- Edgardo Ramos
- 1:25-cv-01108
- U.S. District Court · Southern District of New York
- 2
In Jane Doe v. The Trustee of Columbia University, Judge Ramos denied without prejudice Jane Doe’s request for pro bono counsel because she had not sought fee-waiver status.
Jane Doe’s request for appointed pro bono counsel was denied without prejudice. The order did not decide the merits of her claims against The Trustee of Columbia University in the City of New York or John Doe 1.
What happened
In Jane Doe v. The Trustee of Columbia University in the City of New York, Jane Doe, who was representing herself, sued the university’s trustee and John Doe 1. She asked the court to appoint a free lawyer for the case.
The court explained that a person generally must first show an inability to afford a lawyer by applying for permission to proceed without paying court fees. The court had not received or approved such an application from Jane Doe.
Judge Edgardo Ramos denied Jane Doe’s request for pro bono counsel without prejudice. The order allows her to submit an application to proceed without paying court fees; the court did not decide whether she would ultimately receive appointed counsel.
The detailed version
- Jane Doe v. The Trustees of Columbia University · No. 1:25-cv-01108
- Edgardo Ramos
- Mar. 3, 2025
Background
Jane Doe filed the complaint while representing herself against The Trustee of Columbia University in the City of New York and John Doe 1. She later applied for full-scope pro bono counsel, meaning a lawyer appointed to represent her throughout the litigation.
Court’s reasoning
The court applied 28 U.S.C. § 1915(e)(1), which authorizes courts to request volunteer counsel for qualifying litigants. The court explained that a person seeking pro bono counsel must first show that they cannot afford a lawyer, such as by successfully applying for permission to proceed without paying court fees. If that application is approved, the court would then evaluate whether the claim appears likely to have substance and would consider additional factors identified by the Court of Appeals for the Second Circuit, including the person’s ability to investigate and present the case, the complexity of the legal issues, and whether appointment would likely lead to a fair determination.
Jane Doe had not filed an application to proceed without paying court fees and had not been granted that status. The court stated that she could submit such an application using the court’s form.
Ruling
Judge Edgardo Ramos denied Jane Doe’s application for pro bono counsel without prejudice. The order did not decide whether she qualifies for appointed counsel after applying to proceed without paying court fees, and it did not resolve the underlying claims in her complaint.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.