Rangel v. Williams
- Jacquelyn Corley
- 3:21-cv-00278
- U.S. District Court · Northern District of California
- 3
In Rangel v. Williams, Judge Corley dismissed the case without prejudice because Rangel failed to keep the court informed of his address.
Jonathan Rangel’s § 1983 civil-rights case was dismissed without prejudice because he did not maintain a current address or respond to the court’s order. The defendants’ pending motion for summary judgment was not decided in this order.
What happened
Jonathan Rangel, a California prisoner representing himself, brought a civil-rights case under a federal law that allows claims against state officials. The court had his address and prisoner number, but mail was returned as undeliverable.
Rangel did not oppose the defendants’ summary-judgment motion after receiving an extension, and he had not contacted the court for more than six months. The court gave him 28 days to provide a valid address and explain why the case should not be dismissed, but that order also came back as undeliverable, and he did not respond.
Judge Jacquelyn Scott Corley dismissed Rangel’s case without prejudice under the court’s local address rule and the federal rule allowing dismissal for failure to prosecute or follow court orders. The court said Rangel could refile in a new case if he provides and maintains his correct address.
The detailed version
- Rangel v. Williams · No. 3:21-cv-00278
- Jacquelyn Corley
- Feb. 28, 2024
Background
Jonathan Rangel, a California prisoner proceeding without an attorney, brought this civil-rights action under 42 U.S.C. § 1983. The opinion states that the court mailed its most recent order on October 17, 2023, using the prisoner number and address Rangel had provided. The postal service returned the order as undeliverable on October 26, 2023.
Rangel had requested and received an extension of time to oppose the defendants’ motion for summary judgment, but he did not file an opposition. He also had not contacted the court for more than six months. At the beginning of the case, the court had instructed him to keep the court informed of address changes and warned that failing to do so could lead to dismissal.
Order to Show Cause
On January 17, 2024, the court ordered Rangel, within 28 days, to provide a current valid mailing address and any identification number needed to receive mail, and to explain why the case should not be dismissed under Northern District of California Civil Local Rule 3-11 or Federal Rule of Civil Procedure 41(b). The order warned that failing to respond would result in dismissal.
The postal service returned that order as undeliverable on January 25, 2024. Rangel still did not provide a current address or contact the court.
Court’s Analysis
Civil Local Rule 3-11 requires a self-represented party whose address changes during a case to promptly file and serve a notice of the new address. Under that rule, the court may dismiss a complaint without prejudice when court mail is returned as undeliverable and the court does not receive a written communication from the self-represented party giving a current address within 60 days.
Rule 41(b) also permits involuntary dismissal of an action or claim when the plaintiff fails to prosecute the case or comply with court rules or orders. The court found that Rangel had not provided his current mailing address, had been given time and an opportunity to correct that problem, and had not offered a reasonable explanation for his failure to comply. The court concluded that there were grounds for dismissal under both Civil Local Rule 3-11(b) and Rule 41(b).
Disposition
The court dismissed the case without prejudice to refiling in a new case in which Rangel provides and maintains his correct address. The Clerk was directed to enter judgment and close the file.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.