Seals v. Crumps
- Laura Swain
- 1:25-cv-07850
- U.S. District Court · Southern District of New York
- 2
In Seals v. Crumps, Judge Swain dismissed Tina Seals’s case without prejudice because she did not obtain required permission to file without fees.
Tina Seals; her action was dismissed without prejudice for failure to obtain permission required by an earlier court order.
What happened
Tina Seals filed Seals v. Crumps as a self-represented plaintiff without paying the filing fees. The court treated this as a request to proceed without fees. A 2014 order had barred her from filing a new civil case without fees in this court unless she first obtained permission.
Tina Seals did not seek that permission before filing this case. The court therefore dismissed the action without prejudice for failing to follow the earlier order.
Chief United States District Judge Laura Taylor Swain directed the Clerk of Court to enter judgment. Judge Swain also ruled that an appeal would not be taken in good faith and denied permission to appeal without paying fees.
The detailed version
- Seals v. Crumps · No. 1:25-cv-07850
- Laura Swain
- Sept. 25, 2025
Background
Tina Seals filed this new case without paying the filing fees and represented herself. The court therefore assumed that she was seeking permission to proceed without paying those fees.
In an earlier related proceeding, the court had barred Seals from filing any new civil action without paying fees in the Southern District of New York unless she first obtained permission from the court. Seals did not seek that permission before filing this action.
Ruling
The court dismissed the action without prejudice because Seals failed to comply with the earlier filing restriction. “Without prejudice” means the dismissal itself does not bar a later filing, although the earlier permission requirement remains relevant.
The court also certified under 28 U.S.C. § 1915(a)(3) that any appeal from the order would not be taken in good faith. It therefore denied permission to appeal without paying fees and directed the Clerk of Court to enter judgment.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.