Fontes-Watson v. NYC Dept. of HRA
- Laura Swain
- 1:25-cv-08461
- U.S. District Court · Southern District of New York
- 3
In Tawanna Fontes-Watson v. NYC Dept. of HRA, Judge Swain ordered a signature within 30 days or dismissal without prejudice.
Tawanna Fontes-Watson, who must sign and submit the required page within 30 days to avoid dismissal without prejudice; the case will not proceed to summons or an answer unless she complies.
What happened
In Tawanna Fontes-Watson v. NYC Dept. of HRA et al., the court found that Fontes-Watson’s complaint was unsigned even though she was representing herself. Federal Rule of Civil Procedure 11 requires an unrepresented party to sign a complaint.
The court directed Fontes-Watson to sign and submit the provided signature page within 30 days. No summons or answer will issue yet. If she complies, the Clerk’s Office will process the case; if she does not, the action will be dismissed without prejudice.
Judge Laura Taylor Swain also ruled that any appeal would not be taken in good faith and denied permission to proceed without paying fees for an appeal.
The detailed version
- Fontes-Watson v. NYC Dept. of HRA · No. 1:25-cv-08461
- Laura Swain
- Oct. 22, 2025
Background
Tawanna Fontes-Watson filed this action without a lawyer. The court determined that the complaint she submitted was unsigned. Federal Rule of Civil Procedure 11(a) requires every pleading, including a complaint, to be signed personally by an unrepresented party. The court cited the Supreme Court’s explanation that the rule requires a handwritten name or a mark placed by hand.
Order
The court directed Fontes-Watson to sign and submit the attached signature page within 30 days of the order. The signature page includes a certification concerning the purpose of the complaint, the legal and factual support for the claims, and compliance with Rule 11. It also states that each plaintiff must sign and date the complaint and that a separate application is required to seek permission to proceed without prepaying filing fees.
No summons or answer shall issue at this time. If Fontes-Watson complies, the case will be processed under the Clerk’s Office procedures. If she fails to comply within the allowed time, the action will be dismissed without prejudice, meaning the order does not state that refiling is barred.
Appeal ruling
The court 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 proceed without prepaying fees for an appeal. The order was signed by Chief United States District Judge Laura Taylor Swain.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.