Jeffcoat v. Hunt County Jail

IN THE UNITED STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT OF TEXAS
DALLAS DIVISION
CHANCE JEFFCOAT, 	§
ID # 70169, # 2588162, 	§
Petitioner, 	§
§
v. 	§ 	No. 3:25-CV-2610-S-BW
§
TERRY JONES, 	§
Respondent. 	§ 	Referred to U.S. Magistrate Judge1
FINDINGS, CONCLUSIONS, AND RECOMMENDATION
OF THE UNITED STATES MAGISTRATE JUDGE
Based on the relevant filings and applicable law, the Court should DISMISS
this habeas action without prejudice under Federal Rule of Civil Procedure 41(b) for
failure to prosecute or follow orders of the Court.
I. BACKGROUND
On September 25, 2025, the Court received correspondence from Chance
Jeffcoat, a pretrial detainee in the Hunt County Jail, that was initially opened as a
petition for a writ of habeas corpus under 28 U.S.C. § 2241. (See Dkt. No. 3.) On
October 1, 2025, the Court entered a Notice of Deficiency and Order informing
Jeffcoat that if he was challenging his pretrial detention, he had not filed his petition
on the appropriate form and either paid the $5.00 filing fee or submitted an
application to proceed in forma pauperis (“IFP”) with the required certificate of
inmate trust account (“CTA”) or comparable form. (See Dkt. No. 5 at 1.) 	The
1 By Special Order No. 3-251, this habeas case has been automatically referred for
full case management.
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October 1 order required Jeffcoat to complete and return, within 30 days, a form
habeas petition under 28 U.S.C. § 2241 and to pay the full filing fee or file an IFP
application with a CTA. (See id.) With the order, the Court provided the appropriate
forms for filing a § 2241 habeas petition and an IFP application with a CTA. (See
Dkt. Nos. 5-1, 5-2.) The order further warned Jeffcoat that failure to comply could
result in a recommendation that his case be dismissed under Federal Rule of Civil
Procedure 41(b). (See Dkt. No. 5 at 2.)
The Court received Jeffcoat’s form § 2241 petition on October 16, 2025, along
with correspondence stating that the Court could take the $5.00 filing fee from his
inmate account. (See Dkt. No. 6.) On October 23, 2025, the Court entered a Second
Notice of Deficiency and Order informing Jeffcoat that he was responsible for
remitting payment of the filing fee to the Court and that the Court had not received
payment of the filing fee. (See Dkt. No. 7.) The October 23 order required Jeffcoat
to pay the $5.00 filing fee within 30 days and again warned Jeffcoat that failure to
comply could result in a recommendation that his case be dismissed under Rule
41(b). (See id.)
Over six weeks have passed since the expiration of the deadline in the Court’s
October 23 order, and Jeffcoat still has not paid the $5.00 filing fee. It also appears
that Jeffcoat is no longer a pretrial detainee because he has since pled guilty to, and
was sentenced on, the state offense on which he was detained at the time he filed this
action. See State v. Jeffcoat, No. 35654CR (196th Dist. Ct., Hunt Cnty., Tex. Oct. 15,
2025).
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II. INVOLUNTARY DISMISSAL
Rule 41(b) of the Federal Rules of Civil Procedure “authorizes the district
court to dismiss an action sua sponte for failure to prosecute or comply with [a
Federal Rule of Civil Procedure or] a court order.” Griggs v. S.G.E. Mgmt., L.L.C.,
905 F.3d 835, 844 (5th Cir. 2018). This authority flows from a court’s inherent
power to control its docket, prevent undue delays in the disposition of pending cases,
and avoid congested court calendars. Link v. Wabash R.R. Co., 370 U.S. 626, 629-31
(1962). Further, a court’s authority under Rule 41(b) is not diluted merely because a
party proceeds pro se, as “[t]he right of self-representation does not exempt a party
from compliance with relevant rules of procedural and substantive law.” Wright v.
LBA Hospitality, 754 F. App’x 298, 300 (5th Cir. 2019).
Here, Jeffcoat has failed to comply with the Court’s October 23 order to pay
the $5.00 filing fee, despite a warning that failure to do so could result in the
dismissal of his case. By not complying with the Court’s order, Jeffcoat prevents this
action from proceeding and has failed to prosecute his lawsuit. Accordingly, the
Court should exercise its inherent power to prevent undue delays in the disposition
of pending cases and dismiss this action without prejudice under Rule 41(b) for
failure to prosecute or follow court orders.
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III. RECOMMENDATION
The Court should DISMISS this habeas action without prejudice under
Federal Rule of Civil Procedure 41(b) for failure to prosecute or follow orders of the
Court.
SO RECOMMENDED on January 6, 2026.
____________________________________
BRIAN McKAY
UNITED STATES MAGISTRATE JUDGE
INSTRUCTIONS FOR SERVICE AND
NOTICE OF RIGHT TO APPEAL/OBJECT
A copy of this report and recommendation will be served on all parties in the
manner provided by law. Any party who objects to any part of this report and
recommendation must file specific written objections within 14 days after being
served with a copy. See 28 U.S.C. § 636(b)(1); F ED . R. C IV. P. 72(b). To be specific,
an objection must identify the finding or recommendation to which objection is
made, state the basis for the objection, and indicate the place in the magistrate
judge’s report and recommendation where the disputed determination is found. An
objection that merely incorporates by reference or refers to the briefing before the
magistrate judge is not specific. Failure to file specific written objections will bar the
aggrieved party from appealing the factual findings and legal conclusions of the
magistrate judge that are accepted or adopted by the district court, except upon
grounds of plain error. See Douglass v. United Services Automobile Ass’n, 79 F.3d 1415,
1417 (5th Cir. 1996), modified by statute on other grounds, 28 U.S.C. § 636(b)(1)
(extending the time to file objections to 14 days).
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