Quarles v. LaRue County Jailer
5:16-cv-00190
W.D. Ky.May 9, 2017Background
- Pro se petitioner Roshaun Quarles filed a handwritten letter seeking to overturn state convictions, which the Court opened as a 28 U.S.C. § 2254 habeas action on Nov 30, 2016.
- Court mailed a form and fee instructions on Feb 21, 2017, giving Quarles 30 days to return a completed § 2254 form and either pay $5 or file to proceed in forma pauperis.
- The Court’s Feb 21 order was returned as undeliverable on Mar 13, 2017; Quarles has not updated his address or taken further action in the case since filing.
- Local Rule 5.2(e) requires pro se litigants to notify the Clerk and opposing party of address changes; failure may lead to dismissal.
- The Court invoked Rule 41(b) authority to dismiss for failure to prosecute and for noncompliance with court orders and local rules.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether action should be dismissed for failure to prosecute and to notify court of address change | Quarles did not present arguments or filings after initiating the case | Respondent (and court) argues Quarles failed to update address and failed to comply with court order and local rules | Court dismissed the action for abandonment/failure to prosecute |
| Whether pro se status excuses noncompliance with deadlines and simple procedural requirements | Quarles implicitly relies on pro se status (no filings) | Court argues pro se leniency has limits and does not excuse missed deadlines or simple procedures | Court held pro se status does not excuse failure to comply with clear deadlines and rules |
Key Cases Cited
- Jourdan v. Jabe, 951 F.2d 108 (6th Cir. 1991) (recognizes district court power to dismiss sua sponte for failure to prosecute and limits to pro se leniency)
- Pilgrim v. Littlefield, 92 F.3d 413 (6th Cir. 1996) (pro se litigants not entitled to more generous treatment for missed, simple court-imposed deadlines)
- Lyons-Bey v. Pennell, [citation="93 F. App'x 732"] (6th Cir. 2004) (courts have inherent power to manage affairs and dismiss for lack of prosecution)
- Link v. Wabash R.R. Co., 370 U.S. 626 (U.S. 1962) (Supreme Court recognizing power to dismiss actions for failure to prosecute)