Reported / Citable
Background
Morgan Reid sued PAM Health and applied to proceed in forma pauperis, without prepaying filing fees and costs. The application was pending before U.S. Magistrate Judge Andrew M. Edison.
Reid left the first page of the application blank and did not disclose whether she received any income. She reported more than $2,500 in monthly expenses and three dependents, but disclosed no debt, savings, or assets.
The Court’s Holding
The court ordered Reid to file an amended, complete in forma pauperis application by October 8, 2026. A completed application must account for her basic means of support before the court will consider whether she qualifies to proceed without prepaying fees.
The court explained that § 1915 permits scrutiny of claimed indigency and that an incomplete application alone justified denying the request. The reported expenses and dependents, coupled with the absence of disclosed income, debt, savings, or assets, also required further explanation.
Key Takeaways
- An in forma pauperis applicant must fully disclose income and financial circumstances.
- Reported living expenses may warrant scrutiny when the application identifies no means of support.
- Failure to submit a complete amended application by October 8, 2026, will result in dismissal.
Why It Matters
The order underscores that fee-waiver status is not available on an incomplete financial affidavit. Litigants seeking to proceed under 28 U.S.C. § 1915 must provide enough information for the court to assess both indigency and the plausibility of their claimed financial circumstances.