Supreme Court of the United States · Official docket →
Kimberly Jean Brown v. Michelle Montgomery, et al.
IFP petition · United States Court of Appeals for the Seventh Circuit, No. 25-1220 · judgment December 18, 2025
Questions presented
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Whether a federal district court may impose a dismissal with prejudice as a sanction for noncompliance with jurisdictional discovery before determining that it has subject-matter jurisdiction under 28 U.S.C. § 1332. consistent with the jurisdiction-first principle that federal courts must confirm their adjudicatory power before issuing a merits-preclusive termination. Steel Co. v. Citizens for a Better Environment, 523 U.S. 83 (1998)
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Whether the collateral-sanctions doctrine recognized in Willy v. Coastal Corn.. 503 U.S. 131 (1992) and Cooter & Gell v. Hartmarx Corp., 496 U.S, 384 (1990) extends to authorize a with-prejudice dismissal entered before the court determines its subject-matter jurisdiction, where the sanction operates as a litigation-ending, claim-preclusive judgment.
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Whether a litigation-ending sanction for failure to comply with jurisdictional discovery must be (i) just and specifically related to the jurisdictional facts the discovery was designed to test, and, (ii) supported by findings commensurate with dismissal and a reasoned explanation why lesser, compliance-securing measures would be ineffective. Insurance Corp, of Ireland Ltd.v. Compagnie des Bauxites de Guinee, 456 U.S, 694 (1982); Societe Internationale Pour Participations Industrielles et Commerciales, S.A. v. Rogers, 357 U.S. 197 (1958) IL LIST OF PARTIES Petitioner Kimberly Jean Brown was plaintiff in the district court and appellant in the court of appeals. Respondents are Michelle Montgomery; James D. Montgomery & Associates, Ltd.; Erika Williams; JPMorgan Chase Bank, N.A.; and Lila Goldston.
Counsel of record
For petitioner
Kimberly Jean Brown
For respondent
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Case
Subject area
Judicial Power (estimated from the questions presented, in the Supreme Court Database’s categories)
Conference history
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Proceedings
- Apr 13 2026Petition for a writ of certiorari and motion for leave to proceed in forma pauperis filed. (Response due October 30, 2026)