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Spann v. Westchester County Valhalla Jail
1:25-cv-04739
| S.D.N.Y. | Jun 16, 2025
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Background

  • Madison Robert Spann, a prisoner at Westchester County Jail, submitted a pro se civil action to the U.S. District Court for the Southern District of New York.
  • To proceed, prisoners must pay a $405 filing fee or apply to proceed in forma pauperis (IFP) by submitting a signed application and a prisoner authorization form.
  • Spann submitted his IFP application but did not provide the required prisoner authorization.
  • The court ordered Spann to either pay the $405 fee or submit the authorization within 30 days, warning that failure to comply would result in dismissal of the case.
  • The court certified that any appeal of this order would not be taken in good faith and thus denied IFP status for appeal purposes.

Issues

Issue Plaintiff's Argument Defendant's Argument Held
Requirement to submit prisoner authorization to proceed IFP Spann seeks to proceed IFP but did not submit the authorization Not stated Plaintiff must submit authorization or pay fees within 30 days
Consequences of failure to comply N/A N/A Case will be dismissed if not compliant
Right to appeal IFP N/A N/A IFP for appeal is denied
Labeling and submission procedures N/A N/A Authorization must be labeled and submitted properly

Key Cases Cited

  • Coppedge v. United States, 369 U.S. 438 (1962) (appellant demonstrates good faith when seeking review of a nonfrivolous issue)
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Case Details

Case Name: Spann v. Westchester County Valhalla Jail
Court Name: District Court, S.D. New York
Date Published: Jun 16, 2025
Docket Number: 1:25-cv-04739
Court Abbreviation: S.D.N.Y.