Bradley v. City of Philadelphia

Background

Aisha Bradley, who lives in Pennsylvania, filed this action without a lawyer and asked to proceed without paying filing fees. She named 50 defendants, most or all of whom were in Pennsylvania, concerning events that occurred there.

In an order dated November 12, 2024, the court dismissed the action without prejudice because venue was improper. It declined to transfer the case because Bradley had a history of filing, and attempting to transfer, cases in this court concerning events in Pennsylvania despite warnings that venue was improper. The court also ordered Bradley to show cause within 30 days why it should not restrict her future fee-free filings in this court. Bradley did not file the required declaration. The court had previously denied her motion to withdraw the action because the complaint had already been dismissed.

Ruling

Under 28 U.S.C. § 1651, the court barred Bradley from filing future civil actions without paying filing fees in the Southern District of New York unless she first obtains the court's permission. Any request for permission must include a proposed complaint and a copy of the bar order, and must be filed with the court's Pro Se Intake Unit. The court stated that an action filed without first requesting permission will be dismissed for failure to comply with the order.

The court also warned that continued submission of frivolous documents could lead to additional sanctions, including monetary penalties. It directed the Clerk of Court to close the action, terminate the pending motions, and enter judgment. The court certified that an appeal would not be taken in good faith and denied fee-free status for purposes of an appeal.