Patterson v. The State of New York

Background

The court had previously directed Sharita Patterson to show why the action should not be dismissed without prejudice because she had not updated her address as required by a standing order for self-represented litigants. Patterson updated her address on March 27, 2025, by adding a street address for the post-office-box address listed in her complaint. But an order mailed to that new address on July 29, 2025, was returned to the court.

Ruling

The court granted Patterson an additional 30 days to update her address. It stated that if she did not comply, the court would dismiss the action under Rule 41(b) of the Federal Rules of Civil Procedure, without prejudice to her filing a new civil action. The order also explained that Patterson could consent to receiving court documents by email, in which case she would no longer receive them by regular mail.

The court certified under 28 U.S.C. § 1915(a)(3) that an appeal from the order would not be taken in good faith. It therefore denied fee-free status for purposes of an appeal. The order did not decide the underlying claims.

Effect

The order gives Patterson additional time to provide a current address; it does not itself dismiss the action. The opinion identifies D.P. as another plaintiff but does not state that the address directive was issued to D.P.