Lisa N. v. Social Security Administration
- John Docherty
- 0:26-cv-03494
- U.S. District Court · District of Minnesota
- 2
In Lisa N. v. Social Security Administration, Magistrate Judge Docherty denied Lisa N.'s request to proceed without paying court filing fees, finding her income and savings sufficient.
People who file Social Security appeals in federal court and seek to have the filing fee waived based on financial hardship. This order illustrates that courts will deny such requests when an applicant's reported income and savings substantially exceed their expenses, even if future expenses are anticipated.
What happened
In Lisa N. v. Social Security Administration (Case No. 26-CV-3494), Lisa N. applied to the U.S. District Court for the District of Minnesota to have her filing fee waived so she could pursue her Social Security case without paying upfront court costs. The court evaluates such requests by asking whether the applicant can afford those costs without serious financial hardship or being unable to meet basic needs.
The court found that Lisa N.'s finances did not justify a fee waiver. According to her own application, she receives $6,859.52 per month from her spouse's employment, has about $11,859 in checking and savings accounts, and spends roughly $5,100 per month — meaning her income significantly exceeds her expenses. The court also noted that her reported income exceeds 200% of the federal poverty line for a two-person household in Minnesota, and that she has no dependents. While she mentioned an anticipated vehicle purchase, the court found that was not enough to show that paying the fee would cause undue hardship.
Magistrate Judge John F. Docherty denied the application. Lisa N. must pay the $405.00 filing fee within 21 days of the order. If she does not, the judge indicated he will recommend that the case be dismissed without prejudice — meaning it could potentially be refiled — for failure to prosecute.
The detailed version
- Lisa N. v. Social Security Administration · No. 0:26-cv-03494
- John F. Docherty
- Sept. 3, 2026
Background
Lisa N. filed a lawsuit against the Social Security Administration in the U.S. District Court for the District of Minnesota. Simultaneously, she filed an application to proceed without prepaying fees or costs — commonly called a fee-waiver application or IFP (in forma pauperis) application — asking the court to allow her to litigate without paying the standard $405.00 filing fee upfront.
Note: The District of Minnesota uses a policy of identifying nongovernmental parties in Social Security cases by first name and last initial only. "Lisa N." is the court-designated form of this plaintiff's name.
Legal Standard
The court quoted the governing standard: the central question is whether the plaintiff can afford the costs of proceeding without undue hardship or deprivation of the necessities of life, citing Adkins v. E.I. DuPont de Nemours & Co., 335 U.S. 331, 339–40 (1948), as referenced through a Fifth Circuit decision.
Financial Findings
The court reviewed the financial information Lisa N. herself provided in her application:
- Monthly income: $6,859.52 from her spouse's employment - Liquid assets: approximately $11,859 in checking and savings accounts - Monthly expenses: approximately $5,100 - Dependents: none reported
The court observed that, by Lisa N.'s own account, her income substantially exceeds her monthly expenses, and she holds liquid assets from which the $405.00 filing fee could be paid. The court further noted that her income exceeds 200% of the federal poverty line for a two-person household in Minnesota.
Lisa N. also indicated she would need to purchase a new vehicle within the next 12 months. The court acknowledged this but found it insufficient on the current record to establish that denying the fee waiver would cause undue hardship or deprive her of life's necessities.
Ruling
Magistrate Judge John F. Docherty denied Lisa N.'s Application to Proceed in District Court Without Prepaying Fees or Costs (Dkt. No. 2).
The court ordered Lisa N. to pay the $405.00 filing fee within 21 days of the date of the order. If she fails to do so, the court stated it will recommend that the case be dismissed without prejudice for failure to prosecute under Federal Rule of Civil Procedure 41(b). A dismissal without prejudice, if it were to occur, would mean the case is terminated but could potentially be refiled.
What This Order Does and Does Not Decide
This order addresses only the procedural question of whether Lisa N. qualifies for a fee waiver. The court did not reach the merits of her underlying Social Security claim. The case can proceed if she pays the filing fee within the stated deadline.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.