Henderson v. Johnson, 2:24-cv-00543

Michael R. Henderson, while incarcerated at High Desert State Prison, filed a civil-rights lawsuit alleging constitutional violations.
On February 11, 2025, the court ordered Henderson to update his address by March 12, 2025.
Henderson failed to provide an updated address; court mail to him was returned as undeliverable.
The court must be able to contact parties to proceed with litigation; failure to maintain contact impedes case progression.
The inability to communicate with plaintiff prompted consideration of dismissal under the court’s inherent authority to manage its docket.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether plaintiff's case should be dismissed for failure to comply with court order to update address.	Henderson did not respond; implied non-compliance.	Defendants likely argued prejudice from inability to proceed.	Case dismissed without prejudice for failure to update address.

Thompson v. Hous. Auth. of City of Los Angeles, 782 F.2d 829 (9th Cir. 1986) (court's inherent power to control docket includes sanction of dismissal)
Carey v. King, 856 F.2d 1439 (9th Cir. 1988) (dismissal proper for pro se plaintiff's failure to keep address updated)
Malone v. U.S. Postal Service, 833 F.2d 128 (9th Cir. 1987) (dismissal for failure to comply with court order)
In re Phenylpropanolamine Prod. Liab. Litig., 460 F.3d 1217 (9th Cir. 2006) (factors courts must weigh before dismissing for failure to comply with order)
Anderson v. Air West, 542 F.2d 522 (9th Cir. 1976) (presumption of prejudice from unreasonable delay)
Yourish v. Cal. Amplifier, 191 F.3d 983 (9th Cir. 1999) (less drastic alternatives considered before dismissal)
Henderson v. Duncan, 779 F.2d 1421 (9th Cir. 1986) (need not exhaust every alternative before dismissal)