Brown v. World Health Organization
- Laura Swain
- 1:24-cv-07216
- U.S. District Court · Southern District of New York
- 1
In Brown v. World Health Organization, Judge Swain terminated Brown’s relief request and denied proceeding without fees on appeal after dismissal for lack of jurisdiction.
Sharon Brown’s request for preliminary injunctive relief and any appeal from this order were affected; the case was closed.
What happened
In Brown v. World Health Organization, the court had already dismissed the case because it lacked authority to hear it and had directed the Clerk of Court to enter judgment.
Before judgment was entered, Brown filed her third request for a preliminary injunction. After a civil judgment was entered, the court directed the Clerk to terminate that request, and the case was closed.
Judge Laura Taylor Swain also found that an appeal would not be taken in good faith and denied Brown permission to proceed without paying fees for an appeal.
The detailed version
- Brown v. World Health Organization · No. 1:24-cv-07216
- Laura Swain
- Mar. 19, 2025
Background
The court had dismissed this action in an order dated March 7, 2025, for lack of subject-matter jurisdiction, meaning the court determined that it lacked legal authority to decide the case. The court also directed the Clerk of Court to enter judgment.
Before judgment was entered, Sharon Brown filed her third request for preliminary injunctive relief on March 13, 2025. A civil judgment was entered on March 18, 2025.
Ruling
Because judgment had been entered, the court directed the Clerk of Court to terminate Brown’s request for relief, identified as ECF 12. The court stated that the case was closed.
The court certified under 28 U.S.C. § 1915(a)(3) that any appeal from the order would not be taken in good faith. It therefore denied Brown in forma pauperis status for purposes of an appeal, meaning she could not proceed with the appeal without paying the required fees under that status.
Disposition
The court terminated the request for relief, closed the case, and denied permission to proceed without fees on appeal. This order did not address the underlying claims; the opinion states that the action had previously been dismissed for lack of subject-matter jurisdiction.
Read the full 1-page opinion on CourtListener, the free public archive maintained by the Free Law Project.