Washington v. JP Morgan Chase Bank Incorporation

Background

Charmeen Denise Washington filed this civil action without a lawyer. The court had previously granted her permission to proceed without paying the filing fee. A court order mailed to the address she had provided was returned on August 24, 2023, with a notation that Washington no longer lived there and that the Postal Service could not forward the mailing. The opinion states that Washington had not provided an updated address or otherwise contacted the court by the date of this order.

Order

The court stated that Washington was responsible for providing an address where documents could be served and that the case could not proceed if the court and defendants could not serve her. It directed her to notify the court in writing of her current address within 30 days of the order’s date. It also offered her the option of consenting to electronic service by email through an attached form.

Potential dismissal and appeal status

The court did not dismiss the complaint in this order. Instead, it stated that failure to comply within the allowed time would result in dismissal of the complaint without prejudice, allowing Washington to refile it. Judge Laura Taylor Swain also certified under 28 U.S.C. § 1915(a)(3) that an appeal from the order would not be taken in good faith and denied permission to proceed without paying fees for purposes of an appeal. The opinion does not state whether Washington later complied or whether the complaint was later dismissed.