Pleasant v. Burns, No. 2:25-cv-1658-ACA (Apr. 8, 2026)

Case details
Country
United States
Jurisdiction
Federal
Decided
Apr. 8, 2026
Majority
Annemarie Carney Axon (J.) (unanimous Court)
JEANETTA PLEASANT, Plaintiff, v. LAURA SUSAN BURNS, et..., Slip Copy (2026) © 2026 Thomson Reuters. No claim to original U.S. Government Works.12026 WL 948793Only the Westlaw citation is currently available.United States District Court, N.D.Alabama, Southern Division.JEANETTA PLEASANT, Plaintiff,v.LAURA SUSAN BURNS, et al., Defendants.Case No. 2:25-cv-1658-ACA|Filed 04/08/2026Attorneys and Law FirmsJeanetta Pleasant, Pleasant Legal Solutions, Hoover, AL, ProSe.Hunter Ross Myers, Thomas J. Butler, Maynard Nexsen, PC,Birmingham, AL, for Defendant Laura Susan Burns.Roman A. Shaul, Alabama State Bar, Montgomery, AL, forDefendants Autumn A. Caudell, Alabama State Bar.MEMORANDUM OPINIONANNEMARIE CARNEY AXON UNITED STATESDISTRICT JUDGE*1 Plaintiff Jeanetta Pleasant filed a complaint againstDefendants Laura Burns, Autumn Caudell, and the AlabamaState Bar alleging constitutional and state law violations.(Doc. 1). Ms. Pleasant later filed multiple documents thatincluded nonexistent cases, fabricated case quotations, andmisstatements of the holdings of cases, and the court orderedher to show cause why it should not impose sanctionsunder Federal Rule of Civil Procedure 11. Ms. Pleasant hasrepeatedly ignored the court's orders. The court thereforeWILL DISMISS this case WITHOUT PREJUDICE.I. BACKGROUNDMs. Burns moved to dismiss Ms. Pleasant's complaint. (Doc.6). Ms. Pleasant responded to Ms. Burns's motion. (Doc. 10).Ms. Pleasant's response misrepresented the law, which Ms.Burns highlighted in her reply. (Doc. 13 at 2–5). Roughly amonth later, Ms. Pleasant moved for a preliminary injunction.(Doc. 14). In her motion, Ms. Pleasant repeated some of herearlier misrepresentations and quoted language from casesthat do not exist. (Id.). So the court ordered Ms. Pleasant toshow cause why it should not sanction her. (Doc. 18). Theorder outlined each potential violation, and it ordered Ms.Pleasant to specifically “address each potential violation thatthe court outlined” in the order. (Id. at 6).Due to an error in Ms. Pleasant's email address, she did notreceive notice of the court's order to show cause until after thedeadline to respond. Ms. Pleasant filed an untimely “responseto order to show cause” but primarily addressed only theerror in her email address. (See doc. 19). Ms. Pleasant notedthat “any inaccuracies or deficiencies in prior filings werenot intentional and were not made in bad faith but ratheroccurred without the benefit of receiving complete noticeor an opportunity to timely review and correct the issuesidentified” and that she “acted in good faith throughout thislitigation and respectfully requests that the Court consider thenotification error as a mitigating circumstance.” (Id. at 1). Ms.Pleasant added that she was “willing to supplement, clarify,amend, or withdraw any filings the Court determines requirecorrection” and asked the court not to sanction her under Rule11. (Id.).Ms. Pleasant's filing was not responsive to the court's order.As outlined above, the order to show cause required herto “address each potential violation.” (Doc. 18 at 6). Ms.Pleasant did not address a single potential violation. (Seedoc. 19). Nor did she offer any explanation as to why thefilings contained misquotations, unsupported statements ofauthority, and cited a case that does not exist. And herclaim that none of the “inaccuracies or deficiencies” wereintentional or in bad faith cannot be supported by the factthat she was unaware that Ms. Burns brought these errors tothe court's attention. After all, Ms. Pleasant's “inaccuraciesor deficiencies” occurred before Ms. Burns responded andexisted regardless of Ms. Burns's notice of them.Because of the error in her email address, the court extendedMs. Pleasant's deadline to respond by an additional week.(Doc. 20). The order again instructed Ms. Pleasant that “theorder to show cause requires her to specifically address eachpotential Rule 11 violation that the court outlined” in itsprevious order. (Id.). The order also directed Ms. Pleasant tofile a notice with the court when she received the court's order.(Id.). In addition to electronic notification, the court mailedthe order to Ms. Pleasant.
JEANETTA PLEASANT, Plaintiff, v. LAURA SUSAN BURNS, et..., Slip Copy (2026) © 2026 Thomson Reuters. No claim to original U.S. Government Works.2*2 Both the deadline for Ms. Pleasant to file a noticeconfirming receipt of the order and to respond to the court'sorder to show cause passed, and Ms. Pleasant did not complywith either instruction. Instead, Ms. Pleasant filed a responseto Ms. Burns's opposition to a motion that the court hasalready ruled on. (Doc. 21; see also doc. 18 at 1–2). Inpassing, Ms. Pleasant stated that Ms. Burns's allegations thatMs. Pleasant misstated legal authority were “unsupportedand irrelevant to the Rule 15 analysis.” (Doc. 21 at 2).Yet Ms. Pleasant never explained how the allegations were“unsupported.” (See id.).Finally, the court ordered Ms. Pleasant to show cause why itshould not dismiss the case for her failure to comply with thecourt's instruction. (Doc. 23). Ms. Pleasant did not respond tothe order.II. DISCUSSIONUnder the court's inherent authority and Federal Rule ofCivil Procedure 41(b), a court may sua sponte dismiss acase for a party's failure to comply with its orders. BettyK Agencies, Ltd. v. M/V MONADA, 432 F.3d 1333, 1337(11th Cir. 2005). Although dismissal may be with or withoutprejudice, “dismissal with prejudice ... is an extreme sanctionthat may be properly imposed only when: (1) a party engagesin a clear pattern of delay or willful contempt (contumaciousconduct); and (2) the district court specifically finds thatlesser sanctions would not suffice.” Id. at 1337–38 (quotationmarks omitted).Here, the court finds dismissal without prejudice is anappropriate sanction for Ms. Pleasant's behavior. Ms. Pleasantfilings are non-responsive and ignore the court's orders. Thecourt awarded Ms. Pleasant multiple opportunities to respond,and she failed to do so.Although Ms. Burns urges the court to dismiss with prejudice(doc. 22), the court declines to do so. Dismissal withprejudice is “a sanction of last resort, applicable only inextreme circumstances.” Zocaras v. Castro, 465 F.3d 479,483 (11th Cir. 2006) (quotation marks omitted). The courtcannot conclude that lesser sanctions—including dismissalwithout prejudice—will not suffice. Cf. Gratton v. Great Am.Commc'ns, 178 F.3d 1373, 1375 (11th Cir. 1999) (affirming adistrict court's dismissal with prejudice when the district courtfirst attempted lesser sanctions that did not deter the plaintiff'sconduct). Because the court cannot conclude that lessersanctions will not deter Ms. Pleasant's conduct, the courtcannot dismiss the action with prejudice. The court thereforeWILL DISMISS this case WITHOUT PREJUDICE.III. CONCLUSIONFor the reasons above, the court WILL DISMISS this caseWITHOUT PREJUDICE.DONE and ORDERED this April 8, 2026.All CitationsSlip Copy, 2026 WL 948793End of Document© 2026 Thomson Reuters. No claim to original U.S.Government Works.
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