Dominic Black v. Pennsylvania Board of Probatio, 17-2511

Dominic Black, a pro se prisoner, filed a civil rights suit in Jan 2015 challenging Pennsylvania Parole Board procedures; one defendant (Judge Andrew Dowling) was dismissed early.
District Court granted leave (Feb 26, 2016) to file a single, all‑inclusive amended complaint limited to surviving claims and warned failure to do so would result in dismissal for failure to prosecute.
Black filed motions for leave to amend but never filed the required single amended complaint despite being given time and a complaint form.
On Oct 17, 2016 the District Court dismissed the complaint without prejudice for failure to prosecute and denied pending amendment motions as moot; Black moved for reconsideration and to amend/correct, which were later denied or dismissed as moot.
Black appealed; the Third Circuit reviewed for abuse of discretion and evaluated the Poulis factors governing dismissal for failure to prosecute.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether dismissal for failure to prosecute was proper under Fed. R. Civ. P. 41(b) and Poulis factors	Black contended he did not receive the Court's order and thus could not timely file the amended complaint	Court argued Black knowingly sought leave to amend, was personally responsible as a pro se litigant, was given time and forms, and nevertheless willfully failed to file the single amended complaint	Affirmed: dismissal without prejudice was appropriate after weighing Poulis factors (personal responsibility, dilatoriness, willfulness, lack of effective alternatives, ability to refile)
Whether denial of reconsideration (and refusal to relieve under Rule 60(b)) was proper	Black argued he didn’t receive the order granting leave to amend, which could justify relief	Court found Black’s record and actions contradicted his claim and that he failed to show manifest error or newly discovered evidence	Affirmed: motion for reconsideration denied and Rule 60(b) relief not warranted

Mindek v. Rigatti, 964 F.2d 1369 (3d Cir. 1992) (standard of review for dismissal orders)
Lazaridis v. Wehmer, 591 F.3d 666 (3d Cir. 2010) (standard of review for denial of reconsideration)
Briscoe v. Klaus, 538 F.3d 252 (3d Cir. 2008) (district court may dismiss sua sponte for failure to prosecute only after acquiring necessary facts)
Donnelly v. Johns‑Manville Sales Corp., 677 F.2d 339 (3d Cir. 1982) (procedural guidance on dismissal for failure to prosecute)
Poulis v. State Farm Fire & Cas. Co., 747 F.2d 863 (3d Cir. 1984) (six‑factor balancing test for dismissal sanction)
Ware v. Rodale Press, Inc., 322 F.3d 218 (3d Cir. 2003) (not all Poulis factors must be satisfied)
Hicks v. Feeney, 850 F.2d 152 (3d Cir. 1988) (no single Poulis factor is dispositive)
Max’s Seafood Café v. Quinteros, 176 F.3d 669 (3d Cir. 1999) (standards for reconsideration motions)