Williams v. United States of America
- Louis Stanton
- 1:19-cv-00837
- U.S. District Court · Southern District of New York
- 4
In Williams v. United States, Judge Stanton granted Williams’s fee-refund motion to the extent of ordering a $50 refund, but denied a $350 refund.
John T. Williams receives a $50 administrative-fee refund, while the Clerk of Court must process and mail the check after Williams confirms his current address; Williams does not recover the $350 filing fee.
What happened
In Williams v. United States, John T. Williams asked the court to return the $400 he paid to file his case after the court had denied his request to proceed without paying fees upfront. He argued that alleged corruption in the federal judiciary entitled him to repayment.
The court ruled that Williams could not recover the $350 filing fee because, as a prisoner when he filed the case, he would have had to pay that fee in installments even if he had been allowed to proceed without paying upfront. But he was entitled to recover the separate $50 administrative fee, which would not have applied if that request had been granted.
Judge Louis L. Stanton granted Williams’s motion to the extent that he was entitled to the $50 administrative-fee refund. The Clerk was directed to issue the check after Williams confirmed his current mailing address and to terminate the motion.
The detailed version
- Williams v. United States of America · No. 1:19-cv-00837
- Louis Stanton
- May 13, 2020
Background
John T. Williams filed this action without a lawyer while he was a prisoner residing at a residential reentry center. He requested permission to proceed without paying the filing fee upfront. A prior order had treated him as barred by the Prison Litigation Reform Act’s “three strikes” rule from proceeding without prepaying fees while incarcerated, unless he faced an imminent danger of serious physical injury. The court therefore denied that request and dismissed the complaint without prejudice to his paying the filing fee. Williams then paid $350 in filing fees and $50 in administrative fees. The case was reopened, and the amended complaint was later dismissed for failure to state a claim.
Williams moved to recover both payments. He argued that alleged corruption in the federal judiciary entitled him to the return of the $400. The opinion also states that, in appeals from other cases, the United States Court of Appeals for the Second Circuit later determined that the earlier three-strikes determination was erroneous and that Williams was not barred under that rule.
Court’s analysis
The Prison Litigation Reform Act requires a prisoner who files a civil action without prepaying fees to pay the full filing fee, generally through deductions from the prisoner’s account over time. Thus, even if Williams had been allowed to proceed without prepaying, he still would have owed the $350 filing fee in installments. The court therefore concluded that he was not entitled to a return of that amount.
The court treated the $50 administrative fee differently. That fee does not apply to people who are granted permission to proceed without prepaying filing fees. Because Williams would not have been charged that fee had his request been granted, the court concluded that he was entitled to its return.
Disposition
The court granted Williams’s motion to the extent that he was entitled to the return of the $50 administrative fee. It did not order a refund of the $350 filing fee. The court directed Williams to update his address within 30 days. After he confirmed that the Nevada address was current, the Clerk was directed to issue and mail him a certified check for $50. The Clerk was also directed to terminate the motion.
Read the full 4-page opinion on CourtListener, the free public archive maintained by the Free Law Project.