Abdi v. Hennepin County
- Patrick Schiltz
- 0:25-cv-03012
- U.S. District Court · District of Minnesota
- 2
In Abdi v. Hennepin County, Magistrate Judge Wright denied Sharmarke Y. Abdi's request to proceed without paying court filing fees because his income of over $102,000 per year is too high to qualify.
Individuals who file federal lawsuits and seek to waive the court filing fee based on financial hardship. This ruling illustrates that courts will deny such requests when the applicant's income — here, over $102,000 annually — is deemed sufficient to pay the fee without undue hardship.
What happened
In Abdi v. Hennepin County (Case No. 25-cv-03012), plaintiff Sharmarke Y. Abdi filed a lawsuit against Hennepin County and also asked the court for permission to proceed without paying the standard court filing fee — a process sometimes called filing 'in forma pauperis,' meaning 'as a poor person.' Courts grant this kind of request only when paying the fee would cause the applicant serious financial hardship or deprive them of basic necessities.
Abdi's financial disclosure showed that he earned over $102,000 in the past twelve months and expected to earn more than $8,300 the following month. Based on that income level, the court found it could not conclude that paying the filing fee would cause him undue hardship or prevent him from meeting his basic needs.
Magistrate Judge Elizabeth Cowan Wright denied Abdi's request to proceed without paying the filing fee. Abdi now has 21 days from the date of the order (July 31, 2025) to pay the required filing fee. If he does not pay within that time, the magistrate judge has indicated she will recommend that the case be dismissed without prejudice — meaning it could potentially be refiled — for failure to pursue the case.
The detailed version
- Abdi v. Hennepin County · No. 0:25-cv-03012
- Patrick Schiltz
- July 31, 2025
Background
Plaintiff Sharmarke Y. Abdi filed a lawsuit against Hennepin County in the United States District Court for the District of Minnesota. Along with his complaint, Abdi filed an Application to Proceed In Forma Pauperis (IFP) — a request to be excused from paying the court's filing fee on the grounds of financial hardship.
Legal Standard
Federal courts evaluating IFP applications assess whether the applicant can afford the costs of proceeding with the action without undue hardship or deprivation of the necessities of life. The court cited Ayers v. Tex. Dep't of Crim. Justice, 70 F.3d 1268 (5th Cir. 1995), and Adkins v. E.I. DuPont de Nemours & Co., 335 U.S. 331, 339–40 (1948), as the governing standard.
Application of the Standard
Abdi's IFP application disclosed that he earned over $102,000 in the past twelve months and anticipated earning over $8,300 the following month. Based on these figures, Magistrate Judge Wright concluded that paying the filing fee would not cause Abdi undue hardship or deprive him of life's necessities, and therefore denied the application.
Court's Order and Consequences
The court ordered that:
- Abdi's IFP Application (Dkt. 2) is DENIED.
- Abdi must pay the filing fee within 21 days of July 31,
- 3. Failure to pay within that period will result in a recommendation of dismissal without prejudice under Federal Rule of Civil Procedure 41(b) — the rule permitting dismissal for failure to prosecute — meaning the case could potentially be refiled if dismissed on this basis.
Note on Posture
This order addresses only the procedural question of whether Abdi qualifies for a fee waiver. The underlying merits of Abdi's claims against Hennepin County have not been addressed.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.