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S.D.N.Y.Procedural orderFiled Sept. 29, 2025

Brown v. Tiffany Cathey and Devon Strachen

Judge
Paul Engelmayer
Docket
1:24-cv-01154
Court
U.S. District Court · Southern District of New York
Pages
2
Civil Procedure
In one sentence

Brown v. Cathey was dismissed without prejudice for failure to prosecute, Judge Engelmayer ruled.

Who this affects

Kurell Brown, the plaintiff, is affected by the dismissal. Tiffany Cathey and Devon Strachen are the defendants.

What happened

In Kurell Brown v. Tiffany Cathey and Devon Strachen, Brown alleged that his ex-wife and her boyfriend filed false domestic-violence charges against him, causing him to lose parental rights and his livelihood, among other harms.

The court ordered Brown twice to explain why his amended complaint should not be dismissed, including for failing to state a claim and for not obeying the first order. Brown did not respond to either order.

Judge Paul A. Engelmayer dismissed the case without prejudice under Rule 41(b) and the court’s inherent authority because Brown failed to prosecute. The clerk was directed to close the case.

The detailed version

For law students, journalists, and other readers who want the full reasoning

Case
Brown v. Tiffany Cathey and Devon Strachen · No. 1:24-cv-01154
Judge
Paul Engelmayer
Date
Sept. 29, 2025

Background

Kurell Brown began the action on February 14, 2024. In an amended complaint filed on March 31, 2025, Brown alleged that his ex-wife and her boyfriend filed false domestic-violence charges against him. He claimed those charges resulted in the loss of his parental rights and livelihood, among other things.

Procedural history

The court referred the case to Magistrate Judge Gabriel W. Gorenstein for general pretrial supervision. Judge Gorenstein ordered Brown on May 7, 2025, to explain why the amended complaint should not be dismissed for failure to state a claim. Brown did not respond. On June 9, 2025, Judge Gorenstein issued another order requiring Brown to respond by June 21, 2025, and explain why the case should not also be dismissed under Federal Rule of Civil Procedure 41(b) for failing to comply with the earlier order. Brown again did not respond.

Ruling

Under Rule 41(b) and the court’s inherent authority, Judge Paul A. Engelmayer dismissed the case without prejudice for Brown’s failure to prosecute. The clerk was directed to close the case. The opinion does not state whether Brown was represented by a lawyer.

The authoritative version

Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.

Open opinion PDF →
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