Brown v. Williams

Background

Carson Lynn Brown, representing himself, asked to proceed without paying fees so he could file a petition for review after the Sixth Circuit dismissed his appeal for failure to pay a filing fee. The Court recounted a long history of filings: Brown has submitted eight petitions over eight years, was denied fee-free status in 1994, and filed the current petition alleging prison officials denied court access, sabotaged his laundry, and that a judge was biased by calling him an “African Jew.” The Court called these allegations patently frivolous.

Reasoning

The core question was whether to allow Brown to file without paying fees and whether to block further fee-waived filings because of repeated abuse. The Court denied his request to proceed without fees, ordered him to pay the docketing fee and to submit a petition that follows the Court’s formatting rule by November 10, 1997, and relied on prior decisions that permit sanctions for repeated frivolous filings. Because Brown’s pattern of filings has been limited to noncriminal cases, the Court limited its sanction to noncriminal matters.

Real world impact

As a result, the Clerk is directed not to accept any further requests from Brown to waive filing fees in noncriminal matters unless he first pays the required docketing fee and files a petition that complies with the Court’s rules. The order gives Brown a short deadline to pay and cure his filing defects before the Court will consider his petition.

Dissents or concurrances

Justice Stevens filed a brief dissent, stating he disagrees for reasons previously stated in Martin v. District of Columbia Court of Appeals and related cases.