Jefferson v. Benjamin
- David Doty
- 0:25-cv-02534
- U.S. District Court · District of Minnesota
- 2
In Jefferson v. Benjamin, Judge Doty denied David Jefferson's request to appeal without paying fees, finding the appeal frivolous.
Litigants who have had their cases dismissed and seek to appeal without paying the filing fee; specifically relevant to individuals who may lack financial resources but whose underlying claims have been found frivolous.
What happened
In Jefferson v. Benjamin (Civil No. 25-2534), plaintiff David Jefferson asked the court to let him appeal his dismissed case without paying the required filing fee — a process available to people who cannot afford court costs.
Under federal law, a court may waive the filing fee for someone who cannot afford it, but only if the appeal is taken in 'good faith,' meaning the appeal must raise at least one non-frivolous legal or factual argument. The court acknowledged that Jefferson's finances appeared to qualify him for a fee waiver, but separately examined whether his appeal had any legitimate basis.
Judge David S. Doty found that Jefferson's appeal was frivolous for the same reasons the underlying case had already been dismissed (see the earlier order at ECF No. 4), and therefore concluded the appeal was not taken in good faith. As a result, Judge Doty denied Jefferson's application to appeal without prepaying the filing fee.
The detailed version
- Jefferson v. Benjamin · No. 0:25-cv-02534
- David Doty
- Sept. 2, 2025
Background
Plaintiff David Jefferson filed suit against defendant Mickele Benjamin in the District of Minnesota. The underlying case was dismissed by a prior court order (ECF No. 4). Jefferson then sought to appeal that dismissal and filed an application to proceed without prepayment of the appellate filing fee — commonly called an "in forma pauperis" (IFP) application — under 28 U.S.C. § 1915 and Federal Rule of Appellate Procedure 24(a).
Legal Standards
To obtain IFP status (permission to proceed without paying fees), a litigant must satisfy two requirements. First, the litigant must demonstrate financial inability to pay the full filing fee. 28 U.S.C. § 1915(a)(1). Second, the appeal must be taken in "good faith," meaning it must not be frivolous. 28 U.S.C. § 1915(a)(3). Good faith is assessed by an objective standard, not the appellant's own belief that the appeal has merit. Coppedge v. United States, 369 U.S. 438, 444–45 (1962). An appeal is frivolous — and therefore cannot be deemed in good faith — when it "lacks an arguable basis either in law or in fact." Neitzke v. Williams, 490 U.S. 319, 325 (1989).
Analysis and Ruling
The court assumed, without definitively finding, that Jefferson met the financial eligibility threshold because his IFP application indicated he may lack sufficient income or savings to cover the filing fee.
However, the court found that Jefferson's appeal fails the good-faith requirement. Citing the same reasons articulated in the order dismissing the case (ECF No. 4), the court concluded the appeal is frivolous — i.e., it lacks an arguable basis in law or fact. The court did not restate those reasons in this order but incorporated them by reference.
Accordingly, Judge Doty denied Jefferson's application to appeal without prepaying fees (ECF No. 13). The opinion does not address whether Jefferson may pay the fee and proceed with the appeal through other means, nor does it address the merits of the underlying dismissed claims.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.