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S.D.N.Y.Procedural orderFiled Mar. 1, 2021

KALARICKAL v. United States

Judge
Denise Cote
Docket
1:21-cv-01043
Court
U.S. District Court · Southern District of New York
Pages
2
Pro SeCivil Procedure
In one sentence

In KALARICKAL v. United States, Judge Gardephe required pro se plaintiff Alexander Kalarickal to pay fees after finding his application inadequate.

Who this affects

Alexander Kalarickal, who was required to pay the $400 filing and administrative fees or face dismissal of the action if he failed to comply within 30 days.

What happened

In KALARICKAL v. United States, Alexander Kalarickal sued the United States and asked to proceed without paying the filing fees upfront. He was representing himself.

The court explained that a civil case requires payment of $400 or a signed application showing that the plaintiff cannot afford the fees. Kalarickal’s amended application stated that his income exceeded $60,000, so it did not show that he was unable to pay.

Judge Paul G. Gardephe ordered Kalarickal to pay the $400 within 30 days. The court warned that the action would be dismissed if he did not comply and denied fee-free status for any appeal from the order.

The detailed version

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

Case
KALARICKAL v. United States · No. 1:21-cv-01043
Judge
Denise Cote
Date
Mar. 1, 2021

Background

Alexander Kalarickal brought this action against the United States while proceeding without a lawyer. To begin a civil case in the district court, a plaintiff must either pay $400 in filing and administrative fees or request permission to proceed without prepaying those fees through a signed application.

Kalarickal’s earlier application to proceed without prepaying fees had been denied by the Court of Federal Claims before that matter was transferred to the Southern District of New York. On February 10, 2021, this court ordered him to pay the $400 within 30 days. He then submitted an application on February 24 and an amended application on February 25.

Court’s action

The court found that the amended application did not establish that Kalarickal was unable to pay the fees. The application stated that his income was more than $60,000, which indicated that he appeared to have enough funds to pay.

The court therefore ordered Kalarickal to pay the $400 within 30 days of the March 1 order. The opinion does not state that the action was dismissed at that time. Instead, it warned that the action would be dismissed if he failed to comply. If he complied, the case would be processed under the Clerk’s Office procedures.

Appeal-related ruling

The court certified under 28 U.S.C. § 1915(a)(3) that an appeal from the order would not be taken in good faith and denied permission to proceed without prepaying fees for an appeal.

The authoritative version

Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.

Open opinion PDF →
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