No. 25-6617October Term 2025Petition PendingUpdated Sep 11, 2026
In forma pauperis eligibility
Naquea Elaine Johnson v. New Jersey
Case status
Where it stands
Awaiting an order on the petition
- Next
- No decision timeline until the Court agrees to hear the case.
What it's about
Naquea Elaine Johnson has asked the Supreme Court to review a Fourth Circuit case involving her request to proceed in forma pauperis, meaning without paying court fees because of limited financial resources. Her petition argues that courts violated due process and equal protection by calculating her income using gross income that includes mandatory payments; the Court has not yet agreed to decide the case.
Question presented
1. Whether federal courts violate due process and equal protection by denying in forma pauperis status based on gross income that includes mandatory payments under jurisdictionally void orders, when the IFP denial forecloses the § 1983 action seeking to challenge state actors ’ unauthorized exercise of power and prevents access to discovery documenting the jurisdictional violations. 2. Whether M.L.B. v. S.L.J. ‘ s prohibition on wealth barriers to fundamental rights adjudication extends to § 1983 claims challenging state actors ’ deprivation of parental rights through jurisdictionally void orders issued without subject-matter jurisdiction and without constitutionally mandated procedural safeguards. 3. Whether state actors violate § 1983 when they exercise authority over an interstate child removal after an appellate court orders a mandatory jurisdictional hearing that never occurs, issue orders without subject-matter jurisdiction, and deprive a parent of fundamental liberty interests without due process, creating a federal question that is not barred by Rooker-Feldman or the domestic-relations exception.
Timeline
Briefing
What it's about
Naquea Elaine Johnson asks the Supreme Court to review a Fourth Circuit case about her request to proceed in forma pauperis (without paying court fees because of limited resources). She argues that counting gross income that includes mandatory payments unfairly blocked her civil-rights lawsuit.
Argument
The petition and a motion to proceed in forma pauperis have been filed, but oral argument has not been scheduled and the Court has not agreed to hear the case.
Impact
The case concerns whether court-fee decisions can prevent low-income people from bringing civil-rights claims. For example, a parent challenging actions affecting parental rights may be unable to pursue the case or seek discovery if fees are unaffordable.
What's next
Watch for a scheduling order, a response to the petition, or a decision on certiorari (the Court's decision whether to hear the case). No decision window is available yet.
What is at stake in Johnson v. New Jersey?
Johnson challenges the denial of fee-free court access for her civil-rights case. She says the income calculation included mandatory payments and prevented her lawsuit from moving forward.
Who could be affected by the court-fee issue in this case?
People with limited financial resources who seek to bring federal civil-rights claims could be affected. The dispute also concerns a parent alleging deprivation of parental rights.
What happens next in Johnson v. New Jersey?
The Court must decide whether to grant certiorari, meaning agree to review the case. Oral argument has not been scheduled.
Documents
Activity
AI analysis generated: Case Briefing
Court Order added: Main Document
Brief added: Petition
Sources
Primary materials plus reporting. Best-effort analysis: this explainer relies on a mix of primary materials and trusted secondary sources. Official filings and opinions remain authoritative.



