Reported / Citable
Background
Monica Schulmann, proceeding pro se, sued Robert J. Conrad and several other defendants in the Eastern District of Texas. The case was referred to U.S. Magistrate Judge Christine L. Stetson for pretrial management.
On August 7, 2026, Judge Stetson recommended dismissal under Federal Rule of Civil Procedure 41(b). The recommendation concluded that Schulmann had failed to prosecute the case by giving the clerk an incorrect mailing address, contrary to the local rules. Schulmann did not object to the recommendation.
The Court’s Holding
District Judge Michael J. Truncale adopted the report and recommendation after reviewing it for clear error. The court found no clear error.
The court dismissed Schulmann’s claims without prejudice under Rule 41(b) for failure to prosecute. It stated that final judgment would be entered.
Key Takeaways
- A pro se litigant’s failure to provide a correct mailing address can support dismissal for failure to prosecute.
- When no objection is filed to a magistrate judge’s recommendation, the district court may review it for clear error.
- The dismissal was without prejudice, leaving the claims unadjudicated on their merits.
Why It Matters
The order illustrates that pro se status does not excuse compliance with basic case-management obligations, including maintaining a valid mailing address with the court. Failure to do so can halt the litigation and result in dismissal under Rule 41(b).