Brown v. WWW.JUNHAMPTON
Nkosi S. Brown, Managing Intern, White House, Trump.org v. WWW.JUNHAMPTON; WWW.MICHELLE-KENNEY.COM
- Laura Swain
- 1:24-cv-07173
- U.S. District Court · Southern District of New York
- 2
In Nkosi S. Brown v. WWW.JUNHAMPTON, Judge Swain barred Brown from future IFP civil filings without court permission.
Nkosi S. Brown is barred from filing future civil actions without paying filing fees in the Southern District of New York unless he first obtains court permission.
What happened
In Nkosi S. Brown, Managing Intern, White House, Trump.org v. WWW.JUNHAMPTON; WWW.MICHELLE-KENNEY.COM, the self-represented plaintiff’s action had been dismissed as frivolous. The court also noted that five other cases he filed had been dismissed as frivolous or for lack of subject-matter jurisdiction.
The court had ordered Brown to explain by declaration why he should not be restricted from filing future civil actions without paying filing fees. He did not submit the declaration, and an order sent to him was returned as undeliverable. He also had not updated his address with the Clerk’s Office.
Judge Laura Taylor Swain barred Brown from filing future civil actions without paying filing fees in this court unless he first obtains permission. He must attach his proposed complaint and this order to any request for permission. The court also denied fee-free status for an appeal, directed the Clerk to enter judgment, and directed the Clerk to terminate any motions in the case.
The detailed version
- Brown v. WWW.JUNHAMPTON · No. 1:24-cv-07173
- Laura Swain
- Nov. 3, 2025
Background
Nkosi S. Brown filed this action without a lawyer. On August 6, 2025, the court dismissed the action as frivolous. The court stated that Brown had filed five other cases that had been dismissed as frivolous or for lack of subject-matter jurisdiction.
The August 6 order required Brown to submit a declaration within 30 days explaining why he should not be barred from filing future civil actions without paying filing fees, unless he received the court’s prior permission. Brown did not file the declaration. On September 22, 2025, the court received the August 6 order back as undeliverable. The court also stated that Brown had not updated his address with the Clerk’s Office as required by a standing order.
Ruling
Under 28 U.S.C. § 1651, the court barred Brown from filing future civil actions without paying filing fees in this court unless he first obtains leave—that is, permission—from the court. Any motion seeking permission must include a copy of the proposed complaint and a copy of this order, and must be filed with the court’s Pro Se Intake Unit. The court stated that any action filed without the required motion for permission will be dismissed for failure to comply with the order.
The court also directed the Clerk of Court to terminate any motions in the case and enter judgment. It certified that an appeal from the order would not be taken in good faith and denied Brown fee-free status for purposes of an appeal. The court stated that it would consider a declaration responding to the August 6 order if Brown updates his address, moves for reconsideration, and shows that he intends to file the declaration.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.