Pugh v. Coffee County Jail (MAG+)

CourtDistrict Court, M.D. Alabama
DecidedJune 24, 2025
Docket1:25-cv-00050
StatusUnknown

This text of Pugh v. Coffee County Jail (MAG+) (Pugh v. Coffee County Jail (MAG+)) is published on Counsel Stack Legal Research, covering District Court, M.D. Alabama primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Pugh v. Coffee County Jail (MAG+), (M.D. Ala. 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE MIDDLE DISTRICT OF ALABAMA SOUTHERN DIVISION

DEVIN BRANDIS PUGH, ) ) Plaintiff, ) ) v. ) ) CASE NO. 1:25-CV-050-RAH-KFP ) COFFEE COUNTY JAIL, et al., ) ) Defendants. )

RECOMMENDATION OF THE MAGISTRATE JUDGE

On May 29, 2025, the Court granted pro se Plaintiff Devin Brandis Pugh’s Motion for Leave to Proceed in Forma Pauperis and ordered him to file an amended complaint by June 12, 2025. Doc. 21. To date, no amended complaint has been filed. Accordingly, for the reasons explained below, the undersigned recommends dismissal. I. BACKGROUND1 Plaintiff filed a civil action in federal court asserting claims against Coffee County Jail, Butler County Jail, Covington County Jail, and Pike County Jail. Doc. 1. The undersigned ordered Pugh to either submit the filing and administrative fees or submit an application for leave to proceed in forma pauperis by February 18, 2025. Doc. 5. The Court warned Pugh that a failure to comply with the order would result in a recommendation of dismissal. Id.

1 The Court recites only the procedural history pertinent to this Recommendation. About two weeks after the deadline, on March 5, 2025, Plaintiff filed a Motion for Leave to Proceed in Forma Pauperis. Doc. 6. Upon its review, the Court noted that his

application contained information about his income and expenses that did not align with information submitted in other pending cases in the Middle District of Alabama, despite Pugh signing the statement declaring under penalty of perjury that the information in the application was true. Doc. 9. The Court ordered Plaintiff to complete and file the Court’s long-form application for leave to proceed in forma pauperis by May 2, 2025. Id. at 3. The Court warned Plaintiff that a failure to follow the order would result in a recommendation

of dismissal. Id. at 3–4. Plaintiff failed to file the long-form application on time; instead, on April 21, 2025, Plaintiff filed an untitled slip of paper which was docketed as a Motion to Object. Doc. 10. On May 14, 2025, almost two weeks past the deadline, Plaintiff filed the short-form Application to Proceed in District Court without Prepaying Fees or Costs. Doc. 15. On the

same day, the Court received an untitled document which was docketed as a Motion to Reconsider. Doc. 16. A day later, on May 15, the Court received an untitled document which was docketed as a Motion to Amend (Doc. 17), and on May 19, the Court received an untitled document which was docketed as a Motion for Status (Doc. 18). On May 28, 2025, the Court received an untitled document, which was docketed as a Motion for Status

and Motion for Copies.2 Doc. 20.

2 With the exception of the Application to Proceed in District Court without Prepaying Fees or Costs, the “motions” listed in the paragraph are difficult to read and neither “state with particularity the grounds for seeking the order,” Fed. R. Civ. P. 7(b)(1)(B), nor have a caption, Fed. R. Civ. P. 10(a). Thus, they violate Federal Rules of Civil Procedure 7(b) and 10(a), as well as the Court’s Local Rules. See Fed. R. Civ. P. 7(b)(2) (“The rules governing captions and other matters of form in pleadings apple to motions and other Although the application (Doc. 15) did not explicitly comply with the Court’s order, the Court nonetheless granted Plaintiff leave to proceed in forma pauperis, granted

Plaintiff’s construed Motion to Amend, and ordered Plaintiff to file an amended complaint that complied with the Federal Rules of Civil Procedure and the requirements of the order. Doc. 21. The Court expressly warned Plaintiff that a failure to file an amended complaint meeting the stated requirements would result in a recommendation that the action be dismissed. Id. at 3–4.

II. LEGAL STANDARD As all other litigants, pro se plaintiffs must comply with court orders. If a plaintiff fails to comply with a court order, “[a] district court may dismiss [the] action sua sponte under Fed. R. Civ. P. 41(b).” Goodison v. Washington Mut. Bank, 232 F. App’x 922, 922– 23 (11th Cir 2007) (citing Hildebrand v. Honeywell, Inc., 622 F.2d 179, 181 (5th Cir. 1980)); see also Equity Lifestyle Props., Inc. v. Fla. Mowing And Landscape Serv., Inc.,

556 F.3d 1232, 1240 (11th Cir. 2009) (“The court may dismiss a claim if the plaintiff fails to prosecute it or comply with a court order.”). “While dismissal is an extraordinary remedy, dismissal upon disregard of an order, especially where the litigant has been forewarned, generally is not an abuse of discretion.” Moon v. Newsome, 863 F.2d 835, 837 (11th Cir.1989). “A district court has inherent authority to manage its own docket ‘so as to

achieve the orderly and expeditious disposition of cases.’” Equity Lifestyle Props., Inc.,

papers.”); M.D. Ala. L.R. 5.6 (“All pleadings, motions, and other papers presented for filing shall be . . . plainly typewritten, printed, or prepared by a clearly legible duplicating process[.]”); M.D. Ala. L.R. 5.7 (explaining that a motion “must be filed in accordance with the procedures set forth in the Federal Rules of Civil Procedure and these Local Rules.”). 556 F.3d at 1240 (quoting Chambers v. NASCO, Inc., 501 U.S. 32, 43 (1991)). Specifically, in an unpublished opinion, the Eleventh Circuit has affirmed a district court’s dismissal for

failure to follow a court order to file an amended complaint, Taylor v. Spaziano, 251 F. App’x 616 (11th Cir. 2007), and other courts within the Eleventh Circuit have dismissed a case for plaintiff’s failure to file an amended complaint as directed by a court’s order, Mazone v. Hershey Co., 2022 WL 18781099, at *2 (N.D. Ga. Nov. 1, 2022) (“[T]he Court finds that [p]laintiff’s failure to file an amended complaint as directed by this [c]ourt’s order, coupled with his failure to comply with the Federal Rules of Civil Procedure and

this [c]ourt’s Local Rules, constitutes sufficient grounds for dismissal under Rule 41(b).”); Powell v. Harris, 2017 WL 1026314, at *2 (S.D. Fla. Feb. 22, 2017) (recommending dismissal for failure to file an amended complaint), report and recommendation adopted, 2017 WL 998600 (S.D. Fla. Mar. 15, 2017). III. DISCUSSION

The Court warned Plaintiff that noncompliance with the order to file an amended complaint would result in a recommendation that the action be dismissed. Yet Plaintiff failed to take any action by the imposed deadline. This is not the first time Plaintiff has disregarded a Court order. As detailed above, Plaintiff filed his first application for leave to proceed in forma pauperis two weeks past the Court-ordered deadline, he submitted five

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