Reported / Citable
Background
Saadiq Shabazz, proceeding without counsel, filed a complaint against Berkshire Hathaway Direct Insurance Company on March 27, 2026. The complaint was not signed.
Mail sent by the Clerk’s Office to the address Shabazz provided was returned as undeliverable. Shabazz later attempted to file an amended complaint, but declined to sign it and did not supply an updated mailing address. The court struck and unfiled that proposed amended complaint for noncompliance with Federal Rule of Civil Procedure 11(a).
The Court’s Holding
Magistrate Judge Jeffrey L. Cureton recommended that the action be dismissed without prejudice. Rule 11(a) requires an unrepresented party to personally sign each pleading, written motion, or other paper, and directs a court to strike an unsigned paper unless the omission is promptly corrected after notice.
Because Shabazz had not signed his original complaint and refused to sign the proposed amended complaint or provide a current mailing address, the magistrate judge concluded that dismissal without prejudice was warranted. The recommendation was returned to the district judge, and the parties were given until April 27, 2026, to object.
Key Takeaways
- A pro se plaintiff must personally sign a federal complaint under Rule 11(a).
- An unsigned pleading may be struck if the filing defect is not promptly corrected.
- The recommendation was for dismissal without prejudice, not a merits ruling on any claim against the insurer.
Why It Matters
The recommendation illustrates that basic filing requirements apply to self-represented litigants. A party’s failure to sign pleadings and maintain a usable mailing address can prevent a case from moving forward before any substantive dispute is addressed.
Because this was a magistrate judge’s recommendation, the district judge had not yet entered a final dismissal order as of the April 13 filing.