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S.D.N.Y.Procedural orderFiled Dec. 4, 2025

Manigault v. Rickard

Judge
Laura Swain
Docket
1:25-cv-09822
Court
U.S. District Court · Southern District of New York
Pages
5
HabeasPro SeCivil Procedure
In one sentence

In Francis Manigault v. Erik Rickard, Judge Swain ordered Manigault to pay the fee or submit a fee-waiver application within 30 days.

Who this affects

Francis Manigault must either pay the $5 filing fee or submit a signed application to proceed without prepaying fees within 30 days; otherwise, the action will be dismissed. Erik Rickard was not required to answer at this time.

What happened

Francis Manigault v. Erik Rickard concerns Manigault’s petition for a writ of habeas corpus. Manigault filed the petition without paying the $5 filing fee or submitting an application to proceed without prepaying fees.

The court gave Manigault 30 days from December 4, 2025, to pay the fee or submit a signed fee-waiver application. The court said no response from Rickard was required at this time.

Judge Laura Taylor Swain ordered that the case be processed if Manigault complies and said the action will be dismissed if he does not. She also denied fee-waiver status for any appeal from this order.

The detailed version

For law students, journalists, and other readers who want the full reasoning

Case
Manigault v. Rickard · No. 1:25-cv-09822
Judge
Laura Swain
Date
Dec. 4, 2025

Background

Francis Manigault, proceeding without a lawyer, filed a petition for a writ of habeas corpus. The opinion states that he did not pay the required $5 filing fee and did not submit an application to proceed without prepaying fees, commonly called an IFP application.

Order

The court directed Manigault, within 30 days of the order’s date, to either pay the $5 filing fee or complete and submit the attached signed IFP application. If the court grants the application, Manigault may proceed without prepaying fees. The application was to identify docket number 25-CV-9822 (LTS).

The court stated that no answer from Erik Rickard was required at that time. If Manigault complies with the order, the Clerk’s Office will process the case under its procedures. If he does not comply within the allowed time, the action will be dismissed. The court also certified that any appeal from the order would not be taken in good faith and denied IFP status for purposes of an appeal.

Disposition

Judge Laura Taylor Swain did not decide the substance of Manigault’s habeas petition. She ordered payment of the filing fee or submission of an IFP application and stated that the action will be dismissed if Manigault does not comply.

The authoritative version

Read the full 5-page opinion on CourtListener, the free public archive maintained by the Free Law Project.

Open opinion PDF →
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