Burton v. Vacell, 5:17-cv-00178

Petitioner Bobby E. Burton, a pro se state prisoner, filed a § 2254 habeas petition on August 1, 2017 but left most required form fields blank.
The district court issued a Deficiency Order (Aug. 3, 2017) directing Burton to file an amended petition within 30 days and warned dismissal for failure to comply.
Burton did not respond; the court issued a second Deficiency Show Cause Order (Sept. 18, 2017) again directing an amended petition and warning of dismissal.
Burton made no further filings or communications for over three months, and the petition failed to identify the conviction, sentence, or grounds for relief.
The magistrate judge concluded the court could not adjudicate the petition absent the required information and recommended dismissal without prejudice for want of prosecution under Rule 41(b).

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the petition should be dismissed for want of prosecution under Fed. R. Civ. P. 41(b)	Burton did not provide facts or comply with court orders (no substantive argument made)	Respondent implicitly relied on court management and compliance rules; court moved to dismiss	Recommended dismissal without prejudice for want of prosecution due to Burton's failure to comply with orders
Whether pro se status excuses noncompliance with court orders	Burton offered no showing that pro se status justified noncompliance	Court held pro se status does not permit withholding required information or ignoring orders	Pro se status did not prevent dismissal where the prisoner failed to comply or respond
Whether dismissal for failure to prosecute is an abuse of discretion here	Burton made no timely responses or objections	Court invoked its inherent authority to manage docket and previous warnings given to Burton	Dismissal is appropriate and not an abuse of discretion given repeated warnings and lack of response
Whether objections to the magistrate judge’s report must be specific to preserve appellate review	Burton did not file objections	Court asserted controlling standard for objections under 28 U.S.C. § 636(b) and Fifth Circuit precedent	Parties must file specific written objections within 14 days or risk forfeiture of appellate review

Link v. Wabash R.R. Co., 370 U.S. 626 (establishes court's authority to dismiss actions for want of prosecution to control docket)
Clofer v. Perego, 106 F.3d 678 (5th Cir. 1997) (recognizes sua sponte dismissal power under Rule 41(b))
Boudwin v. Graystone Ins. Co., 756 F.2d 399 (5th Cir. 1985) (dismissal power flows from court's inherent docket-control authority)
Larson v. Scott, 157 F.3d 1030 (5th Cir. 1998) (affirmed dismissal where plaintiff ignored court orders after warnings)
Douglass v. United Servs. Auto. Ass'n, 79 F.3d 1415 (5th Cir. 1996) (requirements for specific written objections to a magistrate judge's report)