Robinson v. Shelter Insurance Company
2:25-cv-02111
W.D. Tenn.May 30, 2025Background
- Plaintiff Kendrick Robinson filed a pro se complaint against Shelter Insurance seeking payment for medical bills and vehicle damages arising from a hit-and-run accident.
- Robinson's initial motion to proceed in forma pauperis was granted by the court.
- The court found that Robinson’s complaint did not adequately allege a basis for federal subject matter jurisdiction and ordered him to file an amended complaint by March 14, 2025.
- Robinson failed to file the required amended complaint or take any further action by the deadline, despite explicit warning that failure to do so could result in dismissal.
- As a result, the Magistrate Judge recommended dismissal of the case without prejudice for failure to prosecute under Federal Rule of Civil Procedure 41(b).
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Failure to plead subject matter jurisdiction | Robinson asserted entitlement to insurance payments but did not explain court jurisdiction | Not stated (no defendant response at this phase) | Insufficient pleading; leave to amend was given |
| Failure to prosecute | No response or action after court's order | Not stated (not served) | Dismissal without prejudice recommended |
| Warning of dismissal | Not addressed | Not stated | Plaintiff was clearly warned |
| Appropriateness of lesser sanction | Not addressed | Not stated | Only dismissal deemed effective |
Key Cases Cited
- Chambers v. NASCO, Inc., 501 U.S. 32 (district courts have authority to dismiss sua sponte for failure to prosecute)
- Knoll v. Am. Tel. & Tel. Co., 176 F.3d 359 (Rule 41(b) empowers courts to manage dockets and dismiss when necessary)
- Schafer v. City of Defiance Police Dep’t, 529 F.3d 731 (four-factor test for dismissal under Rule 41(b))
- Harmon v. CSX Transp., Inc., 110 F.3d 364 (lesser sanctions not required before dismissal for noncompliance)