Valine v. President Donald J. Trump
- Laura Swain
- 1:25-cv-08317
- U.S. District Court · Southern District of New York
- 2
In Jacob Valine v. President Trump, Judge Swain granted Valine’s request to withdraw the action and voluntarily dismissed it under Rule 41(a).
Jacob Valine’s action against President Donald J. Trump and the other defendants was voluntarily dismissed; the clerk was directed to take the specified administrative actions, and Valine was denied permission to appeal without paying court fees.
What happened
Jacob Valine asked the court to withdraw his lawsuit against President Donald J. Trump and the other defendants. The opinion does not describe the lawsuit’s underlying claims.
The court granted Valine’s request and voluntarily dismissed the action under Federal Rule of Civil Procedure 41(a). The order states that this type of dismissal is without prejudice, subject to an exception if the same claim had previously been dismissed.
Judge Laura Taylor Swain also directed the clerk not to transfer the case to the District of Columbia, terminated several motions, and denied Valine permission to appeal without paying court fees.
The detailed version
- Valine v. President Donald J. Trump · No. 1:25-cv-08317
- Laura Swain
- Oct. 22, 2025
Background
On October 14, 2025, the court received a letter from Jacob Valine stating that he wished to withdraw his complaint. The opinion does not identify the complaint’s underlying claims or state whether Valine was represented by counsel.
Ruling
The court granted Valine’s request to withdraw the action. It voluntarily dismissed the complaint under Federal Rule of Civil Procedure 41(a). The court’s footnote explains that a voluntary dismissal under Rule 41(a) is without prejudice, meaning the dismissal generally does not bar refiling. It also notes the rule’s exception: if the plaintiff previously dismissed a federal- or state-court action based on or including the same claim, the later dismissal operates as a decision on the merits.
Other Orders
The court directed the clerk not to electronically transfer the action to the United States District Court for the District of Columbia. It also directed the clerk to terminate the motions filed at ECF 6–9 and 12.
The court certified under 28 U.S.C. § 1915(a)(3) that any appeal would not be taken in good faith. As a result, it denied permission to proceed on appeal without paying the required court fees. Judge Laura Taylor Swain signed the order.
Effect of the Order
The action was voluntarily dismissed, and the opinion does not decide the merits of Valine’s claims.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.