Taylor v. Brown, No. 12-1710 (7th Cir. 2015)
Annotate this CaseIllinois inmate Taylor sued prison officials alleging civil-rights violations. His complaint included misjoined claims, one of which was a failure-to-protect claim against Officer Brown. A magistrate issued a show-cause order indicating that he was inclined a remaining claim concerning medical indifference, but that Taylor could avoid a severance order and a second filing fee if he dismissed one of the misjoined claims voluntarily. Taylor drafted a response voluntarily dismissing his claim against Brown. Two days before the judge’s deadline, Taylor gave the document to a prison librarian to be e-filed. He was immediately transferred to another correctional facility. The court clerk never received the dismissal, however, and the judge severed the claim, opened a new case, and assessed a second filing fee. Both Taylor and the officer argued that Taylor’s voluntary dismissal was timely under the prison mailbox rule, but the court never addressed the issue. The Seventh Circuit vacated and remanded, noting that the district court did not provide an opportunity to prove that the late-received documents were filed in a timely manner. The court noted that a nonjurisdictional deadline was at stake, and the opposing party conceded below that the mailbox rule applied.
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