Rajai Strickland v. FNU Hanner, et al.

District Court, W.D. North Carolina·Decided August 3, 2026·No. 5:26-cv-00008·Unknown

Opinion

UNITED STATES DISTRICT COURT WESTERN DISTRICT OF NORTH CAROLINA STATESVILLE DIVISION 5:26-cv-00008-MR-MTO

RAJAI STRICKLAND, ) ) Plaintiff, ) ) vs. ) MEMORANDUM OF ) DECISION AND ORDER ) FNU HANNER, et al., ) ) Defendants. ) ___________________________ )

THIS MATTER is before the Court on its review of the docket in this matter and on Defendants’ Motion to Dismiss [Doc. 24]. I. BACKGROUND On January 12, 2026, pro se Plaintiff Rajai Strickland (“Plaintiff”) filed this lawsuit pursuant to 42 U.S.C. § 1983 by unverified Complaint against three prison officials, FNUs Hanner, Panero, and Sigmon, and the North Carolina Department of Adult Correction (NCDAC).1 [Doc. 1]. Plaintiff’s Eighth Amendment excessive force claims against Defendants Hanner and Panero survived initial review. Plaintiff’s remaining claims and the remaining

1 At the time he filed the Complaint, Plaintiff was a prisoner of the State of North Carolina incarcerated at the Maury Correctional Institution in Hookerton, North Carolina. [Doc. 1 at 7]. Plaintiff was released from state custody on March 4, 2026. [Doc. 16]. Defendants were dismissed. [Doc. 6]. On March 16, 2026, Plaintiff notified the Court that he had been released from custody and provided his new

address at 9212 Arbourgate Meadows Lane, Charlotte, North Carolina. [Doc. 16]. Two days later, on March 18, 2026, the Court received another

address change notice from the Plaintiff. He advised that he had returned to Mecklenburg County Detention Center (MCDC) and provided a new mailing address at a P.O. Box in Phoenix, Maryland.2 [Doc. 17]. On April 2, 2026, Plaintiff again provided another new address to the Court, which is the

physical address of the MCDC at 700 East 4th Street, Charlotte, North Carolina, which the Court understands to be the proper address for legal mail at the Jail. [Doc. 19].

On May 19, 2026, Defendants filed the pending motion to dismiss, arguing that Plaintiff failed to exhaust his administrative remedies pursuant to the Prison Litigation Reform Act (PLRA), 42 U.S.C. § 1997e(a), before filing this action. [Docs. 24, 25]. The next day, this Court entered an order,

in accordance with Roseboro v. Garrison, 528 F.2d 309 (4th Cir. 1975), notifying Plaintiff of his right to respond to Defendants’ motion and cautioning

2 The P.O. Box address provided by the Plaintiff is known to the Court as the address for the Jail’s centralized mail processing hub for non-legal mail. him that his failure to respond would likely result in Defendants being granted dismissal of Plaintiff’s Complaint. [Doc. 26]. The Court ordered that Plaintiff

had thirty (30) days from entry of the Roseboro Order to respond. [Id. at 2]. On June 26, 2026, the Court’s Roseboro Order, which was mailed to Plaintiff at his address of record, was returned undelivered. [Doc. 27]. The

same day, the Clerk consulted the Mecklenburg County Sheriff’s Office (MCSO) website and learned that the Plaintiff had been released from their custody on May 20, 2026. [6/26/2026 (Court Only) Docket Entry]. On July 6, 2026, the Clerk learned through the MCSO website that

Plaintiff had been returned to custody at the MCDC on July 2, 2026. [7/6/2026 (Court Only) Docket Entry]. The same day, the Clerk entered a Notice instructing the Plaintiff that he must notify the Clerk of any changes to

his address within fourteen (14) days of the Notice and that the failure to do so may result in the dismissal of this action. [11/10/2025 Text-Only Notice]. The Clerk also remailed Plaintiff a copy of the Roseboro Order at that time. The deadlines to respond to Defendants’ motion to dismiss and to notify the

Court of his new address have passed. Plaintiff has not responded to Defendants’ motion or notified the Court of his new address. II. DISCUSSION

A. Failure to Prosecute Plaintiffs have a general duty to prosecute their cases. In this regard, a pro se plaintiff must keep the Court apprised of his current address. See

Carey v. King, 856 F.2d 1439, 1441 (9th Cir. 1988) (“A party, not the district court, bears the burden of keeping the court apprised of any changes in his mailing address.”). Where a pro se plaintiff has failed to notify the Court of his change of address, the action is subject to dismissal without prejudice for

failure to prosecute. Accord Walker v. Moak, Civil Action No. 07-7738, 2008 WL 4722386 (E.D. La. Oct. 22, 2008) (dismissing without prejudice a § 1983 action for failure to prosecute under Rule 41(b) of the Federal Rules of Civil

Procedure where the plaintiff did not notify the court of his new address upon his release from jail). Because Plaintiff failed to comply with the Court’s deadline to notify it of his new address, the Court will dismiss this action without prejudice for

Plaintiff’s failure to prosecute. B. Defendants’ Motion to Dismiss The PLRA requires a prisoner to exhaust his administrative remedies

before filing a § 1983 action. 42 U.S.C. § 1997e(a). The PLRA provides, in pertinent part, that “[n]o action shall be brought with respect to prison conditions under section 1983 of this title, or any other Federal law, by a

prisoner confined in any jail, prison, or other correctional facility until such administrative remedies as are available are exhausted.” Id. In Porter v. Nussle, the Supreme Court held that the PLRA’s exhaustion requirement

applies to all inmate suits about prison life. 534 U.S. 516, 532 (2002). The Court ruled that “exhaustion in cases covered by § 1997e(a) is now mandatory.” Id. at 524 (citation omitted). The Porter Court stressed that, under the PLRA, exhaustion must take place before the commencement of

the civil action to further the efficient administration of justice. Id. In Woodford v. Ngo, the Supreme Court held that the PLRA exhaustion requirement requires “proper” exhaustion: “Administrative law . . . requir[es]

proper exhaustion of administrative remedies, which ‘means using all steps that the agency holds out, and doing so properly (so that the agency addresses the issues on the merits).’” 548 U.S. 81, 90 (2006) (quoting Pozo v. McCaughtry, 286 F.3d 1022, 1024 (7th Cir. 2002)). Further, “[t]here is no

question that exhaustion is mandatory under the PLRA and that unexhausted claims cannot be brought in court.” Jones v. Bock, 549 U.S. 199, 211 (2007) (citing Porter, 534 U.S. at 524). Because exhaustion of administrative remedies is an affirmative defense, Defendants have the burden of pleading and proving lack of exhaustion. Id. at 216.

It is well-settled that a prisoner may not exhaust his administrative remedies during the pendency of a Section 1983 action; rather, he must fully exhaust all steps of the administrative process before filing his lawsuit. See

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Rajai Strickland v. FNU Hanner, et al., (W.D.N.C. 2026).

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