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S.D.N.Y.Procedural orderFiled Aug. 29, 2025

Lai v. City of Oakland

Judge
Laura Swain
Docket
1:25-cv-07104
Court
U.S. District Court · Southern District of New York
Pages
1
Civil ProcedurePro Se
In one sentence

In Guangnan Lai v. City of Oakland, Judge Swain dismissed the mistakenly transmitted action without prejudice and denied appeal fee-waiver status.

Who this affects

Guangnan Lai’s action in the Southern District of New York was dismissed without prejudice because it was transmitted there in error. The order did not dismiss Lai’s claims in the pending Northern District of California proceeding, but it denied fee-waiver status for an appeal from this order.

What happened

Guangnan Lai v. City of Oakland was opened in the Southern District of New York after an action was mistakenly transmitted there from the Northern District of California. The court learned that the case was still pending in the Northern District of California and had not been transferred by court order.

The Southern District of New York dismissed the action without prejudice to Lai’s claims in the Northern District of California case. The order did not decide the underlying claims. It also said that any appeal would not be taken in good faith and denied fee-waiver status for an appeal.

Chief United States District Judge Laura Taylor Swain issued the dismissal order on August 29, 2025.

The detailed version

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

Case
Lai v. City of Oakland · No. 1:25-cv-07104
Judge
Laura Swain
Date
Aug. 29, 2025

Background

Guangnan Lai filed this action without a lawyer. On August 27, 2025, the action was transmitted to the Southern District of New York from the Northern District of California, apparently as though it had been transferred. The Southern District then opened the action.

The court later learned that the action remained pending in the Northern District of California and that no order had transferred it to the Southern District. The opinion identifies the related Northern District proceeding as No. 3:25-CV-6780.

Ruling

The court dismissed this action without prejudice to Lai’s claims in the Northern District of California proceeding because the action had been transmitted to the Southern District in error. The court did not decide the underlying claims.

The court also certified under 28 U.S.C. § 1915(a)(3) that an appeal from the order would not be taken in good faith. It therefore denied fee-waiver status for purposes of an appeal.

The authoritative version

Read the full 1-page opinion on CourtListener, the free public archive maintained by the Free Law Project.

Open opinion PDF →
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