Jacqueline Johnson v. Chicago Board of Education, 2013 U.S. App. LEXIS 11670

Johnson, a former Chicago public school employee, sued for employment discrimination.
The district court granted in forma pauperis status and scheduled a status hearing for Oct 18, 2012.
The order warned that failure to appear could lead to dismissal for lack of prosecution.
Johnson did not appear, and the case was dismissed by the district court for want of prosecution.
Johnson moved to reinstate, claiming she was not notified of the Oct 18 hearing; the judge denied.
On appeal, Johnson challenged the notice and the propriety of immediate dismissal; the court found error in the sanction.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Was immediate dismissal for lack of prosecution an abuse of discretion?	Johnson argues the dismissal was improper for a single misstep and no explore of alternatives.	The district court deemed dismissal appropriate under failure to prosecute and warned beforehand.	Reversed and remanded for reinstate.

Ball v. Chicago, 2 F.3d 752 (7th Cir. 1993) (sanctions must fit misconduct and warnings alone are insufficient)
Kruger v. Apfel, 214 F.3d 784 (7th Cir. 2000) (repeated or serious misconduct justification for dismissal)
Bolt v. Loy, 227 F.3d 854 (7th Cir. 2000) (sanctions must fit the offense; not every failure warrants dismissal)
FM Industries, Inc. v. Citicorp Credit Services, Inc., 614 F.3d 335 (7th Cir. 2010) (dismissal requires consideration of alternatives and reason why others would fail)
Kasalo v. Harris & Harris, Ltd., 656 F.3d 557 (7th Cir. 2011) (sanctions should be proportionate and carefully justified)