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Aana-Kepa v. Satterwhite
1:25-cv-00260
| D. Haw. | Jul 23, 2025
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Background

  • 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)
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Case Details

Case Name: Aana-Kepa v. Satterwhite
Court Name: District Court, D. Hawaii
Date Published: Jul 23, 2025
Docket Number: 1:25-cv-00260
Court Abbreviation: D. Haw.