Walker v. United States Congress

Walker · United States District Court for the Southern District of California · October 6, 2025 · No. 3:25-cv-02064-JES-BLM

Summary

The United States District Court for the Southern District of California overruled Steven Walker’s objections to the denial of reconsideration of his in forma pauperis application. The court denied the renewed application because Walker’s income, assets, and expenses showed that he could pay the $405 filing fee while affording his necessities. The court ordered him to pay the fee by October 27, 2025, or the case would be dismissed without prejudice.

Holdings

  1. The court held that requesting an applicant's average gross monthly income for the prior twelve months and expected income for the following month was a permissible means of assessing the applicant's ability to pay and was not shown to be unconstitutional.
  2. The court held that Plaintiff could afford the one-time $405 filing fee while still affording the necessities of life, and therefore denied his renewed motion to proceed in forma pauperis.
  3. The court held that financing a vehicle does not negate legal ownership; Plaintiff remained the legal owner of the 2016 Jeep Wrangler despite the outstanding loan.
  4. The court held that the First Amendment, Article I, Section 8, Clause 9, and Article III do not exempt a civil litigant from paying the filing fee.

Questions Presented

  1. Whether the court's in forma pauperis application was constitutionally insufficient because it requested gross income rather than net income.
  2. Whether the evidence submitted by Plaintiff was sufficient to establish that he could not pay the filing fee while affording the necessities of life.
  3. Whether Plaintiff's 2016 Jeep Wrangler should be treated as an asset despite the vehicle being financed.
  4. Whether the First Amendment, Article I, Section 8, Clause 9, or Article III exempted Plaintiff from paying the civil filing fee because he sued the federal government.

Disposition

other

Cases Cited (4)

  • Escobedo v. Applebees, 787 F.3d 1226, 1234 (9th Cir. 2015)(followed)
  • Eastern R.R. Presidents Conf. v. Noerr Motor Freight, Inc., 365 U.S. 127 (1961)(distinguished)
  • Trump v. Casa, 606 U.S. 831 (2025)(distinguished)
  • Elrod v. Burns, 427 U.S. 347, 361-362 (1976)(distinguished)

Cited In (0)

No citing cases on record yet.

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