Washington v. New York City
- Laura Swain
- 1:25-cv-01246
- U.S. District Court · Southern District of New York
- 2
In Washington v. New York City, Chief Judge Swain gave the unrepresented plaintiff 30 days to sign the complaint or face dismissal without prejudice.
The order directly affects Jamel Washington, who must sign and return the signature page within 30 days for the action to proceed. New York City was named as the defendant, but the opinion does not describe any further effect on it.
What happened
In Washington v. New York City, Jamel Washington sued New York City without a lawyer, but the complaint he submitted was unsigned. Federal court rules require an unrepresented party to sign a complaint.
The court ordered Washington to sign and return the provided signature page within 30 days. The court said that no summons or answer would issue yet, and that the case would proceed through the Clerk’s Office if he complied. If he did not comply, the action would be dismissed without prejudice, meaning it could be filed again.
Chief Judge Laura Taylor Swain also ruled that an appeal would not be considered brought in good faith and denied Washington permission to appeal without paying court fees.
The detailed version
- Washington v. New York City · No. 1:25-cv-01246
- Laura Swain
- July 14, 2025
Background
Jamel Washington brought this action without a lawyer. The complaint submitted to the court was unsigned. Federal Rule of Civil Procedure 11(a) requires every pleading to be signed, including by an unrepresented party personally. The court cited the Supreme Court’s interpretation of that rule as requiring a handwritten name or a handplaced mark.
Order
The court directed Washington to sign and submit the attached signature page within 30 days of the order. No summons or answer would issue at that time. If Washington complied, the action would be processed under the Clerk’s Office’s procedures. If he failed to comply within the allowed period, the court stated that the action would be dismissed without prejudice.
Appeal-related ruling
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 permission to appeal without paying the required court fees.
Disposition
The court entered an order directing the plaintiff to sign the complaint and did not allow the case to proceed until that requirement was satisfied.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.