Bell v. Social Security Administration, Court of Appeals, 690 F. App'x 624

Sharon D. Bell, pro se, appealed the denial of her Social Security benefits and filed a blank, unsigned complaint in federal district court.
The district court dismissed her complaint without prejudice under Fed. R. Civ. P. 41(b) for failure to comply with Rule 8(a).
Bell filed a one-paragraph amended complaint after dismissal; the district court, having entered final judgment and with an appeal pending, denied leave to amend for lack of jurisdiction. That post-judgment order is not before the appellate court.
On appeal, Bell made no legal argument challenging the district court’s reasoning; she primarily asserted she was too ill to work and asked the court to obtain her medical records.
The Tenth Circuit affirmed the dismissal, denied her motion to supplement the record (materials were not before the district court), and denied in forma pauperis status for lack of a nonfrivolous, reasoned argument.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether dismissal under Rule 41(b) for failure to comply with Rule 8(a) was erroneous	Bell contends she cannot work due to illness and seeks relief; does not challenge district court’s legal reasoning	Commissioner (through district court) relies on dismissal for procedural noncompliance	Affirmed: dismissal proper; Bell forfeited substantive challenge by not briefed argument
Whether the appellate court should accept supplemental medical records and grant IFP	Bell moved to supplement record with medical documentation and sought IFP	Appellee argues materials were not before district court; IFP requires nonfrivolous, reasoned appeal	Denied: supplemental materials excluded; IFP denied for lack of nonfrivolous, reasoned argument

Erickson v. Pardus, 551 U.S. 89 (U.S. 2007) (pro se filings are liberally construed)
Garza v. Davis, 596 F.3d 1198 (10th Cir. 2010) (liberal construction of pro se filings)
Garrett v. Selby Connor Maddux & Janer, 425 F.3d 836 (10th Cir. 2005) (court will not act as counsel to construct arguments)
Nixon v. City & County of Denver, 784 F.3d 1364 (10th Cir. 2015) (appellant must explain why district court was wrong)
Reedy v. Werholtz, 660 F.3d 1270 (10th Cir. 2011) (issues not argued are not addressed)
Bronson v. Swensen, 500 F.3d 1099 (10th Cir. 2007) (cursory statements without analysis are forfeited)
Cornhusker Casualty Co. v. Skaj, 786 F.3d 842 (10th Cir. 2015) (appellate court may deny supplementing record with materials not before district court)
DeBardeleben v. Quinlan, 937 F.2d 502 (10th Cir. 1991) (IFP may be denied when appellant lacks a reasoned, nonfrivolous argument)