Shaffer v. Lashbrook, No. 19-1372 (7th Cir. 2020)
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Shaffer sued corrections officials, alleging that an officer attacked him and that others refused to treat his injuries. The court directed Shaffer to notify the court and the defendants if he were released, stating that it would not independently investigate his whereabouts and that failure to notify the court of any address changes could result in a dismissal. Shaffer conducted discovery and flooded the court with filings until he was released on parole 13 months later. The defendants, having had mail returned as undeliverable, moved for an order to show cause why the case should not be dismissed. The case languished for five months. On the deadline for the close of discovery, a defendant filed another motion. A month passed without any response, so the court dismissed Shaffer's case under FRCP 41(b) for failure to prosecute. Shaffer’s parole was revoked. Shaffer filed a notice of his new address, with requests for appointment of counsel and a status hearing 47 days after the entry of judgment. Shaffer asserted that his notices to opposing counsel and the court about his release must have gotten lost in the mail and that prison officials had not forwarded his mail.
The Seventh Circuit affirmed the denial of Shaffer’s motion. Shaffer’s allegation that he tried to notify the court was self-serving and not credible; it was not plausible that the postal service lost multiple, separate mailings. Shaffer had not established that his failure to update the parties stemmed from mistake or excusable neglect.
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