Reported / Citable
Background
John Eric Anderson, proceeding without counsel, filed a civil-rights action under 42 U.S.C. § 1983 while incarcerated at the LeBlanc Unit. The district court referred the case to U.S. Magistrate Judge Zack Hawthorn for consideration.
The magistrate judge recommended dismissing the action as frivolous and for failure to state a claim upon which relief could be granted. A copy of the report and recommendation mailed to Anderson was returned with a notation that he had been discharged, and Anderson did not provide the court with a new address. No objections were filed.
The Court’s Holding
The district court found the magistrate judge’s findings of fact and conclusions of law correct and adopted the report and recommendation. The order stated that a separate final judgment would be entered in accordance with the magistrate judge’s recommendations.
The court also declined to exercise supplemental jurisdiction. The memorandum order did not separately analyze the underlying claims or specify the supplemental claims at issue.
Key Takeaways
- The court adopted the recommendation that Anderson’s § 1983 action be dismissed as frivolous and for failure to state a claim.
- Anderson filed no objections after the mailed report was returned and did not update his address following his discharge.
- The court declined supplemental jurisdiction and directed that a separate final judgment be entered.
Why It Matters
The order illustrates the consequences for a pro se litigant who fails to keep the court informed of a current address and does not object to a magistrate judge’s recommendation. It also reflects the common practice of declining supplemental jurisdiction when federal civil-rights claims do not proceed.