Randle v. Antioch Police Department

Background

Ramello D. Randle, an inmate at the Contra Costa County Jail, filed this civil-rights action under 42 U.S.C. § 1983 while proceeding without an attorney. The opinion’s caption identifies Brock Marcotte and other defendants.

On September 19, 2024, the court mailed orders extending the defendants’ deadline to file a dispositive motion to the jail address Randle had provided. That same day, Randle told the court that he expected to be released on September 26, 2024, and would update his address in this and two other pending cases. The extension orders were later returned as undeliverable, and Randle did not provide a new address.

Court’s Analysis

The court had ordered Randle to provide a valid current mailing address and any identification number needed to receive mail, or to explain why the case should not be dismissed without prejudice. That order was also returned as undeliverable. Randle did not provide an address, contact the court, or give a reasonable explanation for failing to comply.

Northern District of California Civil Local Rule 3-11 requires a party proceeding without a lawyer to promptly file a notice of a new address when the address changes. The rule permits dismissal without prejudice when court mail is returned as undeliverable and the court receives no written communication identifying a current address within 60 days. The court also found grounds for dismissal under Federal Rule of Civil Procedure 41(b), which allows involuntary dismissal for failure to prosecute a case or comply with court rules or orders.

Disposition

Pursuant to Civil Local Rule 3-11(b) and Rule 41(b), the court dismissed the case without prejudice to refiling in a new case in which Randle provides and maintains a correct address. The clerk was directed to enter judgment and close the file. The order did not decide the underlying civil-rights claims.