Stewart v. Washington
2:25-cv-10116
E.D. Mich.Jul 7, 2025Background
- Maurice Allen-Julius Stewart, a pretrial detainee, filed a pro se civil rights lawsuit against multiple Wayne County Jail officials under 42 U.S.C. § 1983, challenging his conditions of confinement.
- The case was initially filed with three other inmates, but was later severed, leaving Stewart as the sole plaintiff in this action.
- The assigned Magistrate Judge ordered Stewart to update his contact information, indicate his intent to proceed, and file an amended complaint clarifying his claims and defendants by a stated deadline.
- Stewart failed to comply with the court's order by the deadline and did not respond in any way.
- On June 11, 2025, the Magistrate Judge recommended dismissal of the case with prejudice for failure to prosecute and for noncompliance with court orders; Stewart was given a 14-day period to object but did not do so.
- On July 7, 2025, the District Court adopted the recommendation and dismissed the case with prejudice, closing the matter.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Failure to comply with court orders | No response or compliance from Stewart | Case should be dismissed | Dismissal with prejudice |
| Failure to prosecute the case | No further prosecution by Stewart | Case should be dismissed | Dismissal with prejudice |
| Effect of lack of objections to R&R | No objections filed by Stewart | No objections filed | R&R adopted without additional review |
| Forfeiture of appellate rights by non-objection | No position stated | No position stated | Right to appeal forfeited by inaction |
Key Cases Cited
- Thomas v. Arn, 474 U.S. 140 (1985) (failure to object to a magistrate judge's report releases the court from conducting independent review)
- Ivey v. Wilson, 832 F.2d 950 (6th Cir. 1987) (court can accept a recommended disposition without reviewing merits if no objections are filed)
- Berkshire v. Dahl, 928 F.3d 520 (6th Cir. 2019) (failure to timely object to R&R results in forfeiture of appellate rights)
