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 complaint without prejudice after Brown failed to file required documents or pay filing fees.
Nkosi Brown's lawsuit against the Embassy of Antigua and Barbuda was dismissed without prejudice because he did not complete the required filing steps or pay the filing fee.
What happened
Brown v. Embassy of Antigua and Barbuda concerned the plaintiff’s failure to complete the steps required to begin the lawsuit. The court had ordered Brown to submit a fee-waiver application or pay the $405 filing fee and to file a signed complaint.
Brown did none of those things within the required thirty days. The court therefore dismissed the complaint without prejudice, meaning the dismissal did not bar refiling.
Judge Laura Taylor Swain also ruled that any appeal would not be taken in good faith, denied permission to proceed without paying appeal fees, and directed the clerk to enter judgment.
The detailed version
- Brown v. Embassy of Antigua and Barbuda · No. 1:25-cv-02436
- Laura Swain
- May 19, 2025
Background
On March 28, 2025, the court ordered Nkosi Brown to do three things within thirty days: submit an application to proceed without paying filing fees, pay the $405 required fee for filing a civil action, or submit a signed complaint. The order warned that failing to comply would result in dismissal.
Ruling
Brown did not submit the fee-waiver application, pay the filing fee, or submit a signed complaint. The court dismissed the complaint without prejudice under 28 U.S.C. §§ 1914 and 1915. The opinion does not describe the underlying claims.
The court also 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 permission to proceed without paying fees for an appeal and directed the clerk to enter judgment.
Read the full 1-page opinion on CourtListener, the free public archive maintained by the Free Law Project.