Aana-Kepa v. Satterwhite
1:25-cv-00260
| D. Haw. | Jul 23, 2025Background
- Adam Aana-Kepa, proceeding pro se, filed a complaint on June 24, 2025, alleging constitutional violations and negligence related to the removal of six minor children from their legal guardian (his mother).
- Plaintiff's mother, the alleged guardian, is not a named party in this lawsuit.
- Plaintiff simultaneously filed for in forma pauperis (IFP) status, but his initial application was denied due to insufficient information.
- Plaintiff renewed his IFP application, providing more details about his financial status, including homelessness and no income.
- The Court granted the renewed IFP application, allowing Plaintiff to proceed without paying filing fees, and directed specific procedures for service of process on the seven named defendants.
- The decision does not resolve the underlying claims but focuses on the procedural matters of filing fees and serving the complaint.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Eligibility for IFP status | Aana-Kepa is indigent, homeless, and unable to pay fees | Not presented at this stage | Court grants IFP application |
| Sufficiency of financial declaration | Plaintiff provided enough detail in renewed application | Not presented at this stage | Declaration deemed sufficient |
| Appropriateness of proceeding without prepayment | Plaintiff meets statutory standard | Not presented at this stage | Plaintiff allowed to proceed IFP |
| Method and effectiveness of service | Plaintiff requires assistance to serve defendants | Not presented at this stage | U.S. Marshal to facilitate service |
Key Cases Cited
- Adkins v. E.I. Du Pont de Nemours & Co., 335 U.S. 331 (standard for IFP application; absolute destitution not required)
- Escobedo v. Applebee's, 787 F.3d 1226 (applicant must show inability to pay, not destitution)
