Crump v. 180 Degrees Halfway House Staff
Willie James Crump v. 180 Degrees Halfway House Staff, David Phaff, Richard Coffey, and Tony Hunter
- Katherine Menendez
- 0:26-cv-01891
- U.S. District Court · District of Minnesota
- 2
Counsel of record per CourtListener. Firm names are approximate.
In Crump v. 180 Degrees Halfway House Staff, Judge Menendez dismissed the case without prejudice because plaintiff Willie James Crump failed to prosecute it.
Plaintiff Willie James Crump, who had this lawsuit dismissed without prejudice and whose request to proceed without paying filing fees was denied. People who file lawsuits and then fail to take required steps to move their cases forward may face similar dismissals.
What happened
In Crump v. 180 Degrees Halfway House Staff, David Phaff, Richard Coffey, and Tony Hunter, plaintiff Willie James Crump filed a lawsuit in the U.S. District Court for the District of Minnesota. A magistrate judge recommended dismissing the case because Crump failed to take the steps needed to move the case forward — a concept courts call failure to prosecute.
Crump did not file any objections to that recommendation by the June 22, 2026 deadline. Because no objections were filed, the district court reviewed the recommendation only for obvious errors, found none, and accepted it.
Judge Katherine M. Menendez dismissed the case without prejudice under Federal Rule of Civil Procedure 41(b), meaning Crump is not permanently barred from refiling. The court also denied Crump's request to proceed without paying court fees (a status that allows low-income litigants to avoid filing costs).
The detailed version
- Crump v. 180 Degrees Halfway House Staff · No. 0:26-cv-01891
- Katherine Menendez
- June 25, 2026
Background
Plaintiff Willie James Crump filed this lawsuit in the District of Minnesota against 180 Degrees Halfway House Staff, David Phaff, Richard Coffey, and Tony Hunter. The opinion does not describe the underlying claims or facts giving rise to the lawsuit.
Magistrate Judge's Recommendation
United States Magistrate Judge John F. Docherty issued a Report and Recommendation (R&R) on June 8, 2026, recommending that the case be dismissed without prejudice under Federal Rule of Civil Procedure 41(b) for failure to prosecute. Rule 41(b) allows a court to dismiss a case when a plaintiff fails to diligently pursue it. The R&R also apparently addressed Crump's request to proceed without paying filing fees (known as in forma pauperis, or IFP status).
Plaintiff's Non-Response
Crump did not file objections to the R&R by the June 22, 2026 deadline. When no objections are filed to a magistrate judge's recommendation, the district court applies a "clear error" standard of review — a deferential standard under which the court looks only for obvious mistakes, not for an independent reassessment of every issue.
Court's Ruling
Judge Menendez found no clear error in the R&R and accepted it in full. The court ordered:
1. Dismissal without prejudice — The action is dismissed under Rule 41(b) for failure to prosecute. A dismissal without prejudice means Crump is not permanently barred from bringing the same claims in a new lawsuit, subject to any applicable time limits (statutes of limitations) that the court did not address in this order. 2. IFP request denied — Crump's request to proceed without paying court fees (Dkt. 2) is denied.
What the Court Did Not Decide
Because the dismissal rests entirely on a failure-to-prosecute procedural ground, the court did not reach the merits of any claim Crump may have had against the defendants. The opinion contains no analysis of the substance of those claims.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.