Watson v. New York City
- Laura Swain
- 1:25-cv-03005
- U.S. District Court · Southern District of New York
- 5
In Watson v. New York City, Judge Swain required the plaintiffs to pay fees or submit prisoner paperwork before the case proceeds.
Plaintiffs Watson, Antrobus, and Grim, who filed the action without lawyers and are identified in the opinion as incarcerated.
What happened
In Watson v. New York City, Plaintiffs Watson, Antrobus, and Grim filed a civil action without paying the required fees or submitting completed applications to proceed without prepayment.
The court explained that the plaintiffs could pay one total of $405, or that each incarcerated plaintiff could separately submit a signed application and authorization allowing filing-fee payments to be deducted from a prison account.
Judge Laura Taylor Swain ordered compliance within the allowed time, directed that no summons issue yet, and stated that a plaintiff’s claims will be dismissed if that plaintiff does not comply. The court also denied fee-free status for an appeal from this order.
The detailed version
- Watson v. New York City · No. 1:25-cv-03005
- Laura Swain
- May 6, 2025
Background
Plaintiffs Watson, Antrobus, and Grim brought this action without lawyers. The opinion states that they were incarcerated at the Rikers Island – George R. Vierno Center. They submitted the complaint without paying the required filing fees and without completed applications to proceed without prepaying fees, known as applications to proceed in forma pauperis (IFP), or prisoner authorizations.
Fee and IFP requirements
The court explained that a civil action generally requires $405 in fees: a $350 filing fee and a $55 administrative fee. All plaintiffs could pay one total of $405. Alternatively, each incarcerated plaintiff could submit a separate, signed IFP application and prisoner authorization. The authorization permits the facility holding the prisoner to provide certified account statements and deduct the $350 filing fee from the prisoner’s account in installments. The $55 administrative fee does not apply to a person granted IFP status.
Court’s order
The court ordered the plaintiffs to comply within the time allowed. It directed that no summons issue at that time. If the plaintiffs comply, the Clerk’s Office will process the case under its procedures. If any plaintiff fails to comply, that plaintiff’s claims will be dismissed. The court also certified that an appeal from the order would not be taken in good faith and denied IFP status for purposes of an appeal.
The opinion includes a caution that a dismissal for frivolousness, maliciousness, or failure to state a claim can count as a “strike” under the federal prisoner-litigation statute. It does not state the specific deadline for compliance or provide the full names of Antrobus and Grim.
Read the full 5-page opinion on CourtListener, the free public archive maintained by the Free Law Project.