Abdi v. Hennepin County
- Patrick Schiltz
- 0:25-cv-03012
- U.S. District Court · District of Minnesota
- 2
In Abdi v. Hennepin County, Magistrate Judge Elizabeth Cowan Wright denied plaintiff Sharmarke Y. Abdi's request to proceed without paying the court filing fee, finding that his income of over $102,000 per year means he can afford the fee without undue hardship.
Plaintiff Sharmarke Y. Abdi, who must pay the court filing fee within 21 days or risk having his case dismissed. Anyone who files a federal lawsuit and seeks to waive the filing fee based on financial hardship may be affected by the legal standard applied here.
What happened
In Abdi v. Hennepin County (Case No. 25-cv-03012), plaintiff Sharmarke Y. Abdi asked the court to waive the filing fee required to bring his lawsuit, a request known as proceeding without prepaying fees (sometimes called an 'in forma pauperis' application). Courts grant such requests only when paying the fee would cause the applicant serious financial hardship or prevent them from meeting basic needs.
The court reviewed Abdi's financial information and found that he earned over $102,000 in the past twelve months and expects to earn more than $8,300 the following month. Based on that level of income, the court concluded that paying the standard filing fee would not cause him undue hardship or deprive him of life's necessities.
Magistrate Judge Elizabeth Cowan Wright denied the fee-waiver application and ordered Abdi to pay the filing fee within 21 days of July 31, 2025. If he does not pay within that time, the judge indicated she will recommend that the case be dismissed without prejudice — meaning it could potentially be refiled — for failure to move the case forward.
The detailed version
This is a procedural order from the United States District Court for the District of Minnesota, issued by Magistrate Judge Elizabeth Cowan Wright on July 31, 2025, in Abdi v. Hennepin County, Case No. 25-cv-03012 (PJS/ECW).
The Request at Issue
Plaintiff Sharmarke Y. Abdi filed an Application to Proceed In Forma Pauperis (IFP) — a formal request to waive the court filing fee on the grounds that paying it would cause financial hardship. IFP status, if granted, allows litigants to file a lawsuit without paying the required filing fee upfront.
Legal Standard
Courts evaluate IFP applications by determining whether the applicant can afford the costs of proceeding without 'undue hardship or deprivation of the necessities of life.' The court cited Ayers v. Texas Dep't of Criminal Justice, 70 F.3d 1268 (5th Cir. 1995), and Adkins v. E.I. DuPont de Nemours & Co., 335 U.S. 331 (1948), as the governing authority for this standard.
Findings
Based on Abdi's own IFP application, the court found that he earned over $102,000 in the past twelve months and anticipated earning more than $8,300 the following month. The court determined that this income level precluded a finding of undue hardship.
Ruling
The court denied the IFP application. Abdi was ordered to pay the filing fee within 21 days of the order date (July 31, 2025). The order warns that failure to pay within that deadline will result in a recommendation of dismissal under Federal Rule of Civil Procedure 41(b) — the rule governing dismissal for failure to prosecute — and that such a dismissal would be without prejudice (meaning the case could theoretically be refiled, subject to applicable rules and deadlines).
Note on Case Structure
The case number includes the initials of two judges (PJS/ECW), suggesting the matter is assigned to a district judge (initials PJS) with a magistrate judge (Elizabeth Cowan Wright, ECW) handling pre-trial matters. This order was issued solely by Magistrate Judge Wright.
Reviewer note from the AI+
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.