Kamau v. Ertifai

CourtDistrict Court, D. Arizona
DecidedAugust 14, 2025
Docket2:25-cv-02863
StatusUnknown

This text of Kamau v. Ertifai (Kamau v. Ertifai) is published on Counsel Stack Legal Research, covering District Court, D. Arizona primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Kamau v. Ertifai, (D. Ariz. 2025).

Opinion

1 WO 2 3 4 5 6 IN THE UNITED STATES DISTRICT COURT 7 FOR THE DISTRICT OF ARIZONA

9 John Kamau, No. CV-25-02863-PHX-SHD

10 Plaintiff, ORDER

11 v.

12 Hamid R Ertifai, et al.,

13 Defendants. 14 15 Pending before the Court are Plaintiff John Kamau’s application to proceed in forma 16 pauperis (“IFP”), (Doc. 2), and emergency motion for a temporary restraining order 17 (“TRO”) and preliminary injunction (“PI”), (Doc. 7). For the reasons explained below, 18 Kamau’s application to proceed IFP is denied, Kamau’s Complaint is dismissed without 19 prejudice, and the motion for TRO and PI is dismissed as moot. 20 I. BACKGROUND 21 On August 11, 2025, Kamau filed this action. (Doc. 1.) 22 In the Complaint, Kamau alleges that the basis for the Court’s subject matter 23 jurisdiction is “FRCP 65”; he did not check the box for federal question or diversity 24 jurisdiction. (Id. at 3.) Kamau also does not allege any specific causes of action, instead 25 generally alleging that the defendants are money lenders who engaged in predatory 26 behavior and, when Kamau “fell in to hard times,” he was “forced to file bankruptcy.” (Id. 27 at 4.) Kamau requests a TRO and PI to “Order a stop to a Trustee Sale” scheduled for 28 August 19, 2025, which Kamau asserts is in violation of the automatic stay under the 1 Bankruptcy Code, 11 U.S.C. § 362. (Id. at 5.) 2 The same day, Kamau filed the IFP application and motion for TRO and PI. (Docs. 3 2, 7.) 4 II. IFP APPLICATION 5 Before turning to Kamau’s Complaint, his request to proceed IFP in this case must 6 first be addressed. “There is no formula set forth by statute, regulation, or case law to 7 determine when someone is poor enough to earn IFP status.” Escobedo v. Applebees, 787 8 F.3d 1226, 1235 (9th Cir. 2015). “An affidavit in support of an IFP application is sufficient 9 where it alleges that the affiant cannot pay the court costs and still afford the necessities of 10 life.” Id. at 1234 (citing Adkins v. E.I. DuPont de Nemours & Co., 335 U.S. 331, 339 11 (1948)). Although an applicant “need not be absolutely destitute to obtain benefits of the 12 in forma pauperis statute,” a “plaintiff seeking IFP status must allege poverty with some 13 particularity, definiteness and certainty.” Id. (quotation marks omitted). 14 Having reviewed the application to proceed IFP, (Doc. 2), the application is denied. 15 First, Kamau did not properly complete the application. The application instructed Kamau 16 to “not leave any blanks” and to “[c]omplete all questions in this application.” (Id. at 1.) 17 Kamau left most of the questions blank: he identified an average monthly income from the 18 past 12 months but did not include information for any income expected next month, and 19 he did not include his employment history or information for any financial accounts and 20 any amounts contained therein. (See id. at 1–2.) Moreover, although Kamau stated that he 21 “expect[ed] . . . major changes to [his] monthly income or expenses in [his] assets or 22 liabilities during the next 12 months,” he did not follow the application’s instructions to 23 “describe on an attached sheet” what these major changes would be. (Id. at 5.) Kamau’s 24 failure to properly complete the application does not permit a thorough analysis of whether 25 Kamau has enough income or assets, as compared to expenses, to warrant IFP status. See, 26 e.g., Burns v. Gore, 2025 WL 1908400, at *1–2 (S.D. Cal. 2025) (denying IFP application 27 in part because of the “lack of detail Plaintiff provide[d] regarding his income and 28 expenses,” including the plaintiff leaving several sections of the application blank). 1 Second, what little Kamau did complete in the application weighs against granting 2 IFP status. Kamau’s average monthly income over the past year amounts to $93,600. (See 3 Doc. 2 at 1–2.) Although Kamau disclosed that he has two daughters who rely on him for 4 support, he only disclosed the age of one of his daughters, who is 17, so it is unclear 5 whether both are minor dependents. (See id. at 3.) Kamau owns real property valued at 6 $700,000 and (presumably) $1.9 million, respectively. (See id.)1 He also owns a 2019 7 Cadillac Escalade valued at $45,000. (Id.) Although Kamau states that his monthly 8 expenses total $22,500, (id. at 5), it is unclear whether all these expenses constitute the 9 “necessities of life,” Escobedo, 787 F.3d at 1234. For example, although Kamau’s rent or 10 mortgage payment is listed as $13,000 per month, Kamau disclosed that he owns at least 11 two properties, suggesting that at least some of the listed $13,000 rent/mortgage expenses 12 pertain to a separate property than Kamau’s home. (See Doc. 2 at 3–4.) The same analysis 13 applies to the $5,000 in utilities expenses Kamau disclosed. (See id. at 4.) 14 Ultimately, although the disclosed monthly expenses are greater than the disclosed 15 monthly income, it does not appear that all of the disclosed monthly expenses fall within 16 the “necessities of life” that justify IFP status. See Valentine v. Granville Realty, Inc., 2025 17 WL 1839935, at *2 (E.D. Cal. 2025) (“Courts have consistently held that IFP status should 18 not be granted where an applicant can pay the filing fee with acceptable sacrifice to other 19 expenses.” (emphasis added)). The filing fee amounts to approximately 5% of Kamau’s 20 average monthly income over the past year. (See Doc. 2 at 2.) Kamau’s significant assets 21 and monthly income over the past year show that he is not indigent and thus can afford the 22 $405 filing fee. See, e.g., Tod M. v. Kijakazi, 2021 WL 6622288, at *1 (S.D. Cal. 2021) 23 (denying IFP application where the plaintiff indicated he had “assets including a home 24 valued at $250,000, a vehicle valued at $1,500, and a second vehicle valued at $1,200”). 25 Simply because a person lives above their means—as Kamau’s income compared to his 26 expenses implies, given the extremely high expenses for rent/mortgage and utilities—does 27 not mean that the person “cannot pay . . . court costs and still afford the necessities of life.” 28 1 In the box for the value of Kamau’s home, he put “$1.90.” (Doc. 2 at 3.) 1 See Escobedo, 787 F.3d at 1234; see also Berner v. Comm’r of Soc. Sec. Admin., 2023 WL 2 3246978, at *1 (D. Ariz. 2023) (noting that, although Escobedo could be read to hold that 3 if the applicant’s “rent and debt payments exceed her income, Plaintiff is eligible for in 4 forma pauperis status,” this reading would, “taken to its extreme . . . mean someone earning 5 millions of dollars per year would qualify for in forma pauperis status as long as they are 6 spending more than they earn”); Thistle v. Arkansas, 2022 WL 867009, at *2 (S.D. Cal. 7 2022) (denying IFP application where the plaintiff’s monthly income was $4,620.00 and, 8 “[a]lthough Plaintiff . . . elected to pay a substantial portion of his income toward a monthly 9 mortgage payment, given [his] level of income, it appear[ed] he [was] financially able to 10 pay the Court costs”). 11 As the court in Berner reasoned, there is nothing to indicate that Kamau cannot pay 12 the filing fee “without forgoing eating like the plaintiff in Escobedo.” See 2023 WL 13 3246978, at *2. Kamau has not established his poverty with certainty, Escobedo, 787 F.3d 14 at 1234, and the IFP application is thus denied. 15 III. COMPLAINT AND MOTION FOR TRO/PI 16 Although Kamau’s IFP application is denied for the reasons explained above, he 17 will not be given the ability to pay the filing fee to allow this action to proceed because his 18 Complaint is dismissed. 19 “Federal courts are courts of limited jurisdiction.” United States v.

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Kamau v. Ertifai, Counsel Stack Legal Research, https://law.counselstack.com/opinion/kamau-v-ertifai-azd-2025.