Carolyn L. Fields v. Hunter Conrad, 21-10825

Carolyn Fields, a pro se former deputy clerk terminated in January 2020, sued 28 individuals (county clerk, in-house counsel, judge, and other court/county employees) alleging workplace discrimination, retaliation, and related claims.
The district court sua sponte struck Fields’s initial complaint for violating Fed. R. Civ. P. 8 and 10 (no numbered paragraphs, no discrete counts, unclear allegations as to defendants) and ordered amendment.
Fields filed a first amended complaint (nine counts) and a second amended complaint (306 numbered paragraphs); both were struck for the same pleading defects (failure to plead discrete, non-conclusory facts identifying which claims were brought against which defendants). The court held a telephonic hearing and warned Fields of dismissal.
Fields’s third amended complaint (84 pages, 1,000+ numbered paragraphs, 28 defendants) asserted statutory discrimination theories but pleaded a single count (intentional infliction of emotional distress) and contained numerous conclusory, irrelevant, and undifferentiated allegations.
The district court dismissed the third amended complaint with prejudice as a shotgun pleading, concluding Fields had been unable or unwilling to comply after multiple warnings and opportunities to amend. The Eleventh Circuit affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether dismissal for shotgun pleading was an abuse of discretion	Fields reiterated factual grievances but did not address the district court’s shotgun-pleading findings on appeal	Complaint was a shotgun pleading (vague, conclusory, failed to separate claims or identify liable defendants); dismissal proper after repeated opportunities	Affirmed: no abuse of discretion in dismissing as shotgun pleading
Whether Fields’s pro se status excused compliance with Rules 8 and 10	Pro se pleadings deserve liberal construction	Pro se status does not exempt a litigant from following procedural rules	Held: pro se status did not relieve Fields of pleading requirements
Whether Fields abandoned challenge to district court’s findings on appeal	Fields’s briefs rehashed factual allegations but did not address the district court’s shotgun/ noncompliance findings	Appellees argued appellant failed to brief the controlling procedural issues	Held: Court found the issues abandoned because Fields did not plainly raise or brief them on appeal
Whether the court gave adequate opportunity to replead before dismissing with prejudice	Fields had multiple amendment attempts	District court provided repeated written orders, a hearing, and a final opportunity; problems persisted or worsened	Held: district court adequately warned and gave opportunities; dismissal with prejudice appropriate

Weiland v. Palm Beach Cnty. Sheriff’s Office, 792 F.3d 1313 (11th Cir. 2015) (defines shotgun pleadings and purpose of Rules 8 and 10).
Barmapov v. Amuial, 986 F.3d 1321 (11th Cir. 2021) (standard of review for dismissals labeled shotgun pleadings).
Vibe Micro, Inc. v. Shabanets, 878 F.3d 1291 (11th Cir. 2018) (district courts must give plaintiff an opportunity to replead before dismissing with prejudice on shotgun-pleading grounds).
Henley v. Payne, 945 F.3d 1320 (11th Cir. 2019) (pro se pleadings are liberally construed but must comply with procedural rules).
Albra v. Advan, Inc., 490 F.3d 826 (11th Cir. 2007) (pro se litigants must conform to court rules).
Timson v. Sampson, 518 F.3d 870 (11th Cir. 2008) (issues not briefed on appeal are abandoned).
Sapuppo v. Allstate Floridian Ins. Co., 739 F.3d 678 (11th Cir. 2014) (appellant must plainly identify issues on appeal to avoid abandonment).