Brown v. Embassy of Antigua and Barbuda
- Laura Swain
- 1:25-cv-02436
- U.S. District Court · Southern District of New York
- 5
In Brown v. Embassy of Antigua and Barbuda, Judge Swain ordered Brown to pay fees or seek fee waiver and submit a signed complaint page.
Nkosi Brown must satisfy the fee-or-IFP requirement and sign the complaint before the case can proceed; the Embassy of Antigua and Barbuda is not required to answer at this stage.
What happened
In Nkosi Brown v. Embassy of Antigua and Barbuda, Nkosi Brown filed the case without a lawyer but did not pay the required fees or submit an application to proceed without prepaying them. The complaint was also unsigned.
The court gave Brown 30 days to either pay $405 or submit the provided application to proceed without prepaying fees. Brown must also submit a signed copy of the complaint’s signature page. No summons or answer will be issued at this time.
Chief Judge Laura Taylor Swain ordered these steps and stated that the case will be dismissed without prejudice if Brown does not comply within the allowed time. She also denied fee-waiver status for any appeal from this order.
The detailed version
- Brown v. Embassy of Antigua and Barbuda · No. 1:25-cv-02436
- Laura Swain
- Mar. 28, 2025
Background
Nkosi Brown brought this action without a lawyer. Brown submitted a complaint but did not submit the fees required to start a civil case or an application to proceed without prepaying those fees. The complaint also did not contain Brown’s signature.
Fees
The court explained that starting a civil action requires either payment of $405—consisting of a $350 filing fee and a $55 administrative fee—or a signed application to proceed without prepaying fees, commonly called an IFP application. Within 30 days after the order’s date, Brown must pay the $405 or submit the provided IFP application, labeled with docket number 25-CV-2436 (LTS). If the court grants that application, Brown may proceed without paying the fees in advance.
Signature and case processing
Federal Rule of Civil Procedure 11(a) requires an unrepresented party to sign pleadings. The court therefore directed Brown to sign and submit the attached signature page within 30 days. No summons or answer will issue at this time. If Brown complies, the Clerk’s Office will process the case under its procedures. If Brown does not comply within the allowed period, the action will be dismissed without prejudice.
Appeal-related ruling
The court certified that an appeal from this order would not be taken in good faith and denied authorization to proceed without prepaying fees for an appeal. Judge Laura Taylor Swain signed the order.
Read the full 5-page opinion on CourtListener, the free public archive maintained by the Free Law Project.