Reported / Citable
Background
Pro se plaintiff Anthony Washington filed this action on April 10, 2026. On May 27, the court ordered him either to register an email address and become an electronic case filing (ECF) filer under the local civil rules or to seek an exemption from those requirements by June 17.
Washington did not comply. The court issued a second compliance order on June 24, directing him to register as an ECF filer or seek an exemption by July 8. As of July 13, Washington again had not complied.
The Court’s Holding
U.S. Magistrate Judge Jeffrey L. Cureton recommended that the action be dismissed because Washington failed to comply with the court’s orders requiring compliance with the local rules.
The magistrate judge did not enter a final dismissal. Instead, the order set a July 27 deadline for written objections under 28 U.S.C. § 636(b)(1) and returned the matter to the district judge’s docket for further proceedings.
Key Takeaways
- The order is a recommendation of dismissal, not a final dismissal order.
- Washington’s repeated failure to comply with ECF-related orders was the stated basis for the recommendation.
- Parties had until July 27, 2026, to file specific written objections.
Why It Matters
The order illustrates that pro se status does not excuse repeated noncompliance with court orders and local filing requirements. But because the ruling is a magistrate judge’s recommendation, the district judge retains the final decision after considering any timely objections.