Brown v. Embassy of Antigua and Barbuda
- Laura Swain
- 1:25-cv-02436
- U.S. District Court · Southern District of New York
- 1
In Brown v. Embassy of Antigua and Barbuda, Judge Swain dismissed the action and denied IFP status for an appeal.
Nkosi Brown’s action against the Embassy of Antigua and Barbuda was dismissed, and Brown was denied permission to appeal without paying filing fees.
What happened
In Brown v. Embassy of Antigua and Barbuda, the court entered judgment dismissing Nkosi Brown’s action against the Embassy of Antigua and Barbuda. The opinion says the reasons were stated in a May 19, 2025, order, which is not included here.
The court also certified that an appeal would not be taken in good faith and denied Brown permission to appeal without paying the required filing fees. The judgment does not state the basis for dismissing the action.
Judge Laura Taylor Swain signed the judgment on May 20, 2025. The available opinion does not provide further details about the claims or the dismissal’s legal reasoning.
The detailed version
- Brown v. Embassy of Antigua and Barbuda · No. 1:25-cv-02436
- Laura Swain
- May 20, 2025
Disposition
The court entered a civil judgment dismissing the action. It stated that the reasons for the dismissal were set out in a May 19, 2025, order, but that order is not included in the provided text. The judgment therefore does not reveal whether the dismissal was based on a threshold issue, the merits, or another ground.
Appeal-related ruling
The court certified under 28 U.S.C. § 1915(a)(3) that an appeal from the judgment would not be taken in good faith. It consequently denied in forma pauperis status—that is, permission to proceed with the appeal without paying filing fees—for purposes of an appeal. The court cited a Supreme Court decision stating that good faith exists when an appellant seeks review of a nonfrivolous issue.
Classification
This is classified as a procedural order because the provided judgment dismisses the action without explaining the underlying legal basis, and it separately makes an appeal-related filing-fee determination. The May 19 order would be needed to assess the dismissal’s reasoning.
Read the full 1-page opinion on CourtListener, the free public archive maintained by the Free Law Project.