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

Jamel Washington v. New York City, et al.

Judge
Laura Swain
Docket
1:25-cv-01246
Court
U.S. District Court · Southern District of New York
Pages
1
Civil Procedure
In one sentence

Washington v. New York City: Judge Swain dismissed the complaint without prejudice because Washington did not submit the required original signature page.

Who this affects

Jamel Washington’s complaint was dismissed without prejudice; the defendants were not otherwise addressed in the opinion.

What happened

In Jamel Washington v. New York City, the court had ordered Washington to resubmit the complaint’s signature page with an original signature within thirty days.

Washington did not submit the signed page, so the court dismissed the complaint without prejudice under the federal rule requiring a party’s signature. The court also said Washington could appeal without paying fees only if the appeal was taken in good faith, and denied that status for an appeal.

Judge Laura Taylor Swain directed the Clerk of Court to enter judgment. The opinion says the filing fee had not been charged because the court had not yet approved Washington’s request to proceed without paying it.

The detailed version

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

Case
Jamel Washington v. New York City, et al. · No. 1:25-cv-01246
Judge
Laura Swain
Date
Sept. 3, 2025

Background

The court had previously ordered Jamel Washington to resubmit the signature page of his complaint with an original signature within thirty days. The earlier order warned that failure to comply would result in dismissal.

Ruling

Washington did not submit the signed signature page. The court therefore dismissed the complaint without prejudice, meaning the opinion did not bar a later filing on that basis. The court cited Federal Rule of Civil Procedure 11(a), which addresses required signatures on court filings.

The court also certified that an appeal from the order would not be taken in good faith. It therefore denied Washington permission to appeal without paying filing fees. The Clerk of Court was directed to enter judgment.

Additional detail

The court stated that it had not yet granted Washington’s request to proceed without paying the filing fee, so the $350 filing fee had not been charged.

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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