Brown v. Donald John Trump
- Laura Swain
- 1:25-cv-07009
- U.S. District Court · Southern District of New York
- 1
In Maxine Brown v. Donald John Trump, Judge Swain dismissed the complaint without prejudice because Brown neither paid filing fees nor submitted a fee-waiver application.
Maxine Brown's complaint was dismissed without prejudice because she did not pay the filing fee or submit the required application to proceed without paying it. Her request to proceed without paying fees on appeal was also denied.
What happened
In Maxine Brown v. Donald John Trump, the court had ordered Maxine Brown to submit an application to proceed without paying filing fees or pay the $405 filing fee within 30 days. The order warned that failing to do so would lead to dismissal.
Brown did not submit the application or pay the fee. The court therefore dismissed the complaint without prejudice, meaning the dismissal did not bar refiling.
Judge Laura Taylor Swain also denied Brown permission to proceed without paying fees for an appeal, finding that an appeal would not be taken in good faith, and directed the clerk to enter judgment.
The detailed version
- Brown v. Donald John Trump · No. 1:25-cv-07009
- Laura Swain
- Oct. 1, 2025
Background
On August 26, 2025, the court directed Maxine Brown to submit a completed application to proceed without paying the filing fee or to pay the $405 required to file a civil action. The court gave her 30 days and stated that failure to comply would result in dismissal.
What the Court Decided
The court found that Brown had neither submitted the application nor paid the filing fee. It dismissed the complaint without prejudice under 28 U.S.C. §§ 1914 and 1915. The opinion does not address the underlying claims against the defendants.
Appeal and Judgment
Judge Laura Taylor Swain certified that any appeal would not be taken in good faith and denied permission to proceed without paying fees for an appeal. The court also directed the clerk to enter judgment in the case.
Read the full 1-page opinion on CourtListener, the free public archive maintained by the Free Law Project.