Sheila M. Larkins v. International Union, United Automobile, Aerospace and Agricultural Implement Workers of America, et al.

District Court, E.D. Michigan·Decided June 30, 2026·No. 4:25-cv-12106·Unknown

Opinion

UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF MICHIGAN SOUTHERN DIVISION

SHEILA M. LARKINS, Case No. 25-12106

Plaintiff, F. Kay Behm United States District Judge v. Curtis Ivy, Jr. INTERNATIONAL UNION, United States Magistrate Judge UNITED AUTOMOBILE, AEROSPACE AND AGRICULTURAL IMPLEMENT WORKERS OF AMERICA, et al.,

Defendants. ____________________________/

REPORT AND RECOMMENDATION: RULE 41(b) DISMISSAL

I. PROCEDURAL HISTORY

Plaintiff Sheila M Larkins filed this pro se employment discrimination and retaliation complaint on July 11, 2025, against Defendants International Union, United Automobile, Aerospace and Agricultural Implement Workers of America (“UAW”), and five named individuals. (ECF No. 1). On October 7, 2025, the District Judge referred all pretrial matters to the undersigned. (ECF No. 8). On January 14, 2026, Defendants UAW, LaKeisha Davis, Dave Pagac, and Laura Dickerson filed their pending Motion to Dismiss Plaintiff’s Complaint (ECF No. 18). Plaintiff’s deadline to respond to Defendant’s motion was February 9, 2026. (ECF No. 18). Similarly, Plaintiff was ordered to provide a new address(es) for service of process on Defendants Matt Gilliam and Marni Schroeder on or

before February 6, 2026. On February 9, 2026, and March 30, 2026, Plaintiff moved for an extension of time to file a response because her son was undergoing medical treatment and she was in Chicago with him during the process, which

were both granted. Plaintiff was provided until May 11, 2026, to file her response brief and to provide new service of process information. Plaintiff did not—and has not—filed a response to Defendants’ motion, provided new service of process information, or moved for another extension.

Because of Plaintiff’s failure to respond to the motion or provide new service of process information, the Court issued an order to show cause why the undersigned should not recommend that the motion be granted or that this case be

dismissed for Plaintiff’s failure to prosecute under Federal Rule of Civil Procedure 41(b). (ECF No. 26). Plaintiff’s response to the show cause order was due June 8, 2026; alternatively, Plaintiff could have filed her response to Defendants’ motion and provide the new service of process information. (Id.). Yet, as of this writing, a

response of any kind remains outstanding. II. ANALYSIS Pursuant to Rule 41(b), a federal court may sua sponte dismiss a claim for

failure to prosecute or comply with an order. Link v. Wabash R.R. Co., 370 U.S. 626, 630–32 (1962); Steward v. City of Jackson, Tenn., 8 F. App’x 294, 296 (6th Cir. 2001). “[D]istrict courts possess broad discretion to sanction parties for

failure to comply with procedural requirements.” Tetro v. Elliott Popham Pontiac, Oldsmobile, Buick, & GMC Trucks, Inc., 173 F.3d 988, 991 (6th Cir. 1999) (citing Carver v. Bunch, 946 F.2d 451, 453 (6th Cir. 1991)). Indeed, the “authority of a

federal trial court to dismiss a plaintiff’s action with prejudice because of his failure to prosecute cannot seriously be doubted.” Link, 370 U.S. at 629–30. “The power to invoke this sanction is necessary in order to prevent undue delays in the disposition of pending cases and to avoid congestion in the calendars of the District

Courts.” Id. Also, a “district court can dismiss an action for noncompliance with a local rule . . . if the behavior of the noncomplying party rises to the level of a failure to prosecute under Rule 41(b) of the Federal Rules of Civil Procedure.”

Tetro, 173 F.3d at 992. It is true that “district courts should be especially hesitant to dismiss for procedural deficiencies where, as here, the failure is by a pro se litigant.” White v. Bouchard, No. 05-73718, 2008 WL 2216281, at *5 (E.D. Mich. May 27, 2008)

(quoting Lucas v. Miles, 84 F.3d 532, 535 (2d Cir. 1996)); see also McCallum v. Gilless, 38 F. App’x 213, 216 (6th Cir. 2002) (regarding the typical leeway afforded to pro se litigants). But a sua sponte dismissal may be justified by a

plaintiff’s “apparent abandonment of [a] case.” Jourdan v. Jabe, 951 F.2d 108, 110 (6th Cir. 1991); White, 2008 WL 2216281, at *5 (citing Washington v. Walker, 734 F.2d 1237, 1240 (7th Cir. 1984)); see also Labreck v. U.S. Dep’t of Treasury,

No. 11-10155, 2013 WL 511031, at *2 (E.D. Mich. Jan. 25, 2013), report and recommendation adopted, 2013 WL 509964 (E.D. Mich. Feb. 12, 2013). The Sixth Circuit considers four factors in reviewing the decision of a

district court to dismiss a case for failure to prosecute: (1) whether the party’s failure is due to willfulness, bad faith, or fault; (2) whether the adversary was prejudiced by the dismissed party’s conduct; (3) whether the dismissed party was warned that failure to cooperate could lead to dismissal; and (4) whether less drastic sanctions were imposed or considered before dismissal.

Wu v. T.W. Wang, Inc., 420 F.3d 641, 643 (6th Cir. 2005) (citing Knoll v. Am. Tel. & Tel. Co., 176 F.3d 359, 363 (6th Cir. 1999)). Here, on balance, these factors weigh in favor of dismissal. As for the first factor, “it is not clear whether [P]laintiff’s failure to prosecute is due to willfulness, bad faith, or fault.” White, 2008 WL 2216281, at *5. Though “at a minimum, [s]he is clearly at fault for failing to . . . comply with the Court’s orders.” Clayborn v. Distelrath, No. CV 19-12971, 2020 WL 584177, at *1 n.1 (E.D. Mich. Jan. 14, 2020), report and recommendation adopted, 2020 WL 570909 (E.D. Mich. Feb. 5, 2020). Plaintiff has been provided four separate deadlines to respond as ordered, but to date she has not complied with the Court’s orders. (ECF Nos. 19, 21, 23, 25–26). As such, the first factor weighs in favor of dismissal.

As for the second factor, Defendant is prejudiced by Plaintiff’s failure to prosecute his case. Defendants “cannot be expected to defend an action” that Plaintiff “has apparently abandoned, not to mention the investment of time and

resources expended to defend this case.” White, 2008 WL 2216281, at *5. Indeed, this Court has deemed such abandonment prejudicial to defendants since it results in pending litigation without movement towards a timely resolution. Id.; Clayborn, 2020 WL 584177, at *1. As previously noted, the Court is sympathetic

with Plaintiff’s situation, but Defendants have a right to challenge the sufficiency of the claims she levied against them as well as receive a timely resolution of that motion. (See ECF No. 25). For these reasons, the second factor also weighs in

favor of dismissal. Based on the explicit warning given to Plaintiff, the third factor also weighs in favor of dismissal. This Court has regularly dismissed cases under Rule 41(b) after a plaintiff has been warned of dismissal, failed to comply with court orders

Free access — add to your briefcase to read the full text and ask questions with AI

Sheila M. Larkins v. International Union, United Automobile, Aerospace and Agricultural Implement Workers of America, et al., (E.D. Mich. 2026).

Sheila M. Larkins v. International Union, United Automobile, Aerospace and Agricultural Implement Workers of America, et al. (Sheila M. Larkins v. International Union, United Automobile, Aerospace and Agricultural Implement Workers of America, et al.) — published by Counsel Stack Legal Research, free access to 12M+ legal documents.

Related

Link v. Wabash Railroad
370 U.S. 626 (Supreme Court, 1962)
Thomas v. Arn
474 U.S. 140 (Supreme Court, 1986)
Eddie Washington v. Daniel Walker
734 F.2d 1237 (Seventh Circuit, 1984)
Randall D. Carver v. Bobby Bunch and Betty Bunch
946 F.2d 451 (Sixth Circuit, 1991)
James M. Jourdan, Jr. v. John Jabe and L. Boyd
951 F.2d 108 (Sixth Circuit, 1991)
Lucas v. Miles
84 F.3d 532 (Second Circuit, 1996)
Steward v. City of Jackson
8 F. App'x 294 (Sixth Circuit, 2001)
McCallum v. Gilless
38 F. App'x 213 (Sixth Circuit, 2002)