Randolph v. Ramona L. Goodman

Background

Jamein Rakin Randolph, representing himself, filed a complaint against Ramona L. Goodman on June 5, 2025. The case was initially assigned to Judge Laura Taylor Swain and was transferred to Judge Jennifer L. Rochon’s court on June 9, 2025.

On August 20, 2025, the court dismissed the complaint for lack of subject-matter jurisdiction. The court allowed Randolph to file an amended complaint by September 19, 2025, and warned that failing to do so would result in judgment for Goodman and closure of the case. The court later extended the deadline to October 10, 2025. Randolph did not file an amended complaint, respond to the court’s orders, or otherwise indicate that he intended to continue the case.

Legal standard

Federal Rule of Civil Procedure 41(b) allows a court to dismiss an action when a plaintiff fails to pursue the case or comply with court rules or a court order. The court must weigh five considerations: how long the failure lasted, whether the plaintiff was warned about dismissal, possible prejudice to the defendant from further delay, the court’s need to manage its docket compared with the plaintiff’s opportunity to be heard, and whether a less severe sanction was considered. Because dismissal under Rule 41(b) is the harshest sanction, the plaintiff must receive notice of the conduct at issue, the standard for dismissal, and an opportunity to respond. For a self-represented litigant, the circumstances must be sufficiently extreme.

Court’s analysis

The court found that several factors supported dismissal. Randolph had not filed the required amended complaint or otherwise responded to the August 20 order. He had also received explicit warnings that failing to comply would result in dismissal, both in the August 20 order and in the later extension order. The court further noted that the case had been pending for nearly five months and that the court had an obligation to resolve cases fairly, promptly, and inexpensively.

Disposition

The court dismissed the action with prejudice under Rule 41(b). It directed the clerk to mail Randolph a copy of the order, terminate all pending motions, and close the case. The court also certified that an appeal would not be taken in good faith and denied Randolph fee-free appeal status. The opinion does not provide a separate discussion of each of the five Rule 41(b) factors beyond the considerations described above.