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S.D.N.Y.Procedural orderFiled Sept. 3, 2025

Alexandra Marie Dean v. Donald Trump, et al.

Judge
Laura Swain
Docket
1:25-cv-05743
Court
U.S. District Court · Southern District of New York
Pages
2
Civil Procedure
In one sentence

In Dean v. Trump, Judge Swain dismissed the complaint without prejudice because Dean neither paid the filing fee nor submitted an application to proceed without paying it.

Who this affects

Alexandra Marie Dean’s complaint was dismissed without prejudice, judgment was entered, and fee-free status was denied for purposes of any appeal. The order did not resolve the underlying allegations against Donald Trump or the other defendants.

What happened

Alexandra Marie Dean sued Donald Trump and other defendants in Dean v. Trump. The court had ordered her to either submit an application to proceed without paying filing fees or pay the $405 fee required to file a civil case.

The court’s order was returned as undeliverable, and Dean did not update her address or otherwise communicate with the court after July 28, 2025. She did not submit the application or pay the fee.

Judge Laura Taylor Swain dismissed the complaint without prejudice and directed the clerk to enter judgment. Judge Swain also denied fee-free status for any appeal because the court certified that an appeal would not be taken in good faith.

The detailed version

For law students, journalists, and other readers who want the full reasoning

Case
Alexandra Marie Dean v. Donald Trump, et al. · No. 1:25-cv-05743
Judge
Laura Swain
Date
Sept. 3, 2025

Background

Alexandra Marie Dean filed a civil complaint against Donald Trump and other defendants. On July 18, 2025, the court ordered Dean, within 30 days, to submit a completed application to proceed without paying filing fees or to pay the $405 fee required to file a civil action in the Southern District of New York. The order warned that failure to comply would result in dismissal.

Failure to Comply

On August 6, 2025, the Clerk’s Office received notice from the United States Postal Service that the July 18 order had been returned as undeliverable. Dean had not updated her address with the court or otherwise communicated with the court since July 28, 2025, when she filed a document titled “In re: Donald J. Trump (In response to veiled threats from Trump).” Dean did not submit the required fee-waiver application or pay the filing fee.

Ruling

The court dismissed the complaint without prejudice under 28 U.S.C. §§ 1914 and 1915. “Without prejudice” means the order did not state that the complaint was permanently barred from being filed again. The court directed the Clerk of Court to enter judgment. It also certified under 28 U.S.C. § 1915(a)(3) that an appeal would not be taken in good faith and denied fee-free status for purposes of an appeal.

Judge Laura Taylor Swain signed the order as Chief United States District Judge.

The authoritative version

Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.

Open opinion PDF →
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