Brown v. Nassau County First District Court Clerk's Office, 2:23-cv-06453

Plaintiff Thurman Jerome Brown filed two separate actions pro se in the Eastern District of New York and sought to proceed in forma pauperis (IFP).
Brown used the AO 240 Short Form IFP application, asserting low or no income, minimal assets, substantial credit card debt, and intent to file for bankruptcy.
Brown previously sought and was denied IFP status in 2020 in another case; he eventually paid the filing fee in that prior case and described using unemployment funds.
The court found Brown's current applications lacking in detail, particularly regarding any changes in financial circumstances and the means by which Brown retained his residence and telephone despite his asserted poverty.
As a result, the court could not determine whether Brown was truly indigent or simply choosing not to pay the filing fee.
Brown was given 14 days to submit a more detailed (Long Form) IFP application or pay the filing fee, with dismissal without prejudice as the consequence for not doing so.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Brown qualifies for IFP status	Brown: Unable to pay fees	Not stated in opinion	Denied without prejudice, not enough detail
Sufficiency of Short Form IFP application	Brown: Submitted required info	N/A	Short Form insufficient, must use Long Form
Change in plaintiff’s financial circumstances	Brown: Current income/debt asserted	N/A	Insufficient explanation of change/status
Opportunity to proceed after denial	Brown: Should be granted IFP or alternative	N/A	May submit Long Form or pay fee within 14 days

Adkins v. E.I. Du Pont De Nemours & Co., 335 U.S. 331 (IFP standard is whether plaintiff can pay without compromising necessities)
Coppedge v. United States, 369 U.S. 438 (appeal not taken in good faith results in IFP denial for appeal)
Lyndonville Sav. Bank & Tr. Co. v. Lussier, 211 F.3d 697 (federal courts must dismiss actions lacking subject matter jurisdiction)