×
You've used up your 3 free articles for this month. Subscribe today.
Eleventh Circuit Declines to Extend to Summary Judgment Proceedings a Rule Requiring District Courts to Notify Pro Se Litigants
Loaded on Nov. 1, 2025
by Douglas Ankney
published in Prison Legal News
November, 2025, page 50
Filed under:
Staff-Prisoner Harassment,
BOP Litigation Reports,
Summary Judgment,
Pro Se Issues,
Unlawful Detention.
Location:
Alabama.
by Douglas Ankney
On February 13, 2025, the U.S. Court of Appeals for the Eleventh Circuit declined to extend to summary judgment proceedings based on Bank v. Pitt, 928 F.2d 1108 (11th Cir. 1991), which requires district courts to sua sponte notify pro se litigants to amend …
Full article and associated cases available to subscribers.
As a digital subscriber to Prison Legal News, you can access full text and downloads for this and other premium content.
Already a subscriber? Login
More from this issue:
- America’s Deadliest Jails: Tarrant County Edition, by Anthony Accurso
- Washington Prisoners Gain Access to Crisis Hotline
- From the Editor, by Paul Wright
- HRDC’s Washington Jail Debit-Release Card Suit Survives Summary Judgment, by Chuck Sharman
- $11 Million Paid to Estate of Mentally Ill Illinois Jail Detainee Who Lost 60 Pounds During 85-Day Incarceration, by Chuck Sharman
- Dying Mississippi Prisoner Wins Preservation Testimony in Suit Blaming Terminal Cancer on Exposure to Janitorial Chemicals, by Chuck Sharman
- Missouri Blocks Spiritual Advisors from Prison Pastor’s Execution, by Jo Ellen Nott
- Ninth Circuit Finds No Bivens Extension Needed for Federal Prisoner Prescribed Water and Exercise for Thyroid Storms, by Chuck Sharman
- Trans Kentucky Prisoner Loses Bid to Block State’s New Ban on Hormone Replacement Therapy, by Chuck Sharman
- Enormous $14 Million Settlement Reached by Los Angeles County with Former Prisoner Exonerated After 20 Years, by Chuck Sharman
- San Diego County Files Unusual Suit Against NaphCare Over Jail Detainee’s Murder, by Chuck Sharman
- For Delay in Summoning Medical Care for Detainees, Alabama Jailers Granted Immunity But California Trooper Headed to Trial, by Chuck Sharman
- Seventh Circuit Rules Against Prisoner’s Deliberate Indifference Claim Over Wexford Health’s Poor Psychiatric Care, by Michael Thompson
- Sixth Circuit Clarifies What Constitutes PLRA “Strike” and Reinstates Michigan Prisoner’s Lawsuit, by Matthew Clarke
- $2.4 Million Paid to Indiana Prisoners Sickened With Legionnaire’s Disease by Contaminated Water, by Chuck Sharman
- Body-Worn Camera Program for Guards Expands to all Maryland Prisons, by Chuck Sharman
- CoreCivic Pays $82,500 for First COVID-19 Death at San Diego ICE Lockup, by Chuck Sharman
- Wisconsin DOC Ordered to Provide Programming for Pregnant Prisoners—34 Years After Law Was Passed, by Chuck Sharman
- Securus Loses Bid to Dismiss HRDC Price-Fixing Suit, by Chuck Sharman
- $150,000 Paid by Jacksonville for Mother of Five’s Jail Suicide, by Chuck Sharman
- Federal Injunction Bars ICE from Crowding Detainees in Unsanitary “Hold” Rooms in New York City Office, by Chuck Sharman
- While Mentally Ill Rikers Island Detainee Lay Dying, Staff Sprayed Air Freshener, Fudged Cell Checks, by Chuck Sharman
- SCOTUS Overturns Oklahoma Prisoner’s Death Sentence After More than 25 Years on Death Row, by Douglas Ankney
- $1.8 Million Settlement Reached Following CDCR Data Breach, by Chuck Sharman
- North Carolina Prison Officials Run Out the Clock On Trans Prisoner’s Vulvoplasty, by Chuck Sharman
- Seventh Circuit Dismisses Jail Detainee Suicide Case for Lack of Showing Deliberate Indifference, by Anthony Accurso
- Fourth Circuit Rules in Favor of Prisoner’s Eligibility for Time Credits, by Douglas Ankney
- Jailhouse Lawyer Gets 16-1/2-Year Sentence for Defrauding Prisoner “Clients”, by Chuck Sharman
- Federal Government, CoreCivic Slow-Walk Class-Action Challenges to Forced Labor of ICE Detainees, by Chuck Sharman
- Oklahoma County Jailers Lose Bids to Derail Three Suits Over Detainee Murders, by Chuck Sharman
- Ohio Appoints Special Prosecutor to Investigate Double Amputee’s Restraint and Death
- Fifth Circuit Remands Louisiana Detainee’s Medical Grievance Case, by Michael Thompson
- South Dakota Approves $650 Million New Prison Construction
- Eighth Circuit Orders Preliminary Injunction Requiring Minnesota to Reinstate Program Teaching Biblical “Authentic Manhood”, by Matthew Clarke
- Appeals Court Rules Michigan’s Tolling Provision Is Not Inconsistent with the PLRA, by Douglas Ankney
- California’s Attorney General Is Suing Los Angeles County Jails Over “Inhumane Conditions”, by Michael Thompson
- FCC Issues Proposed Rule Permitting Cellphone Jammers in Prisons and Jails, by Chuck Sharman
- Preliminary Injunction Halts Solitary Confinement of Mentally Ill Prisoners at New York Lockup Where Wildcat Guard Strike Began, by Chuck Sharman
- Florida Sheriff Fires Five Guards for Two Cases of Detainee Abuse
- $5.5 Million Paid for Two Withdrawal Deaths at Washington Jail, by Chuck Sharman
- $950,000 Awarded to Trans Maryland Prisoner Dropped on Her Face by Guards, by Douglas Ankney
- Seventh Circuit Affirms Liberty Interest in Harsh Solitary Confinement Case, by Michael Thompson
- Eleventh Circuit Overturns 1990 Alabama Death Sentence Over Racially Biased Jury Selection; ACLU Report Shows It Is Still Happening, by Matthew Clarke
- Eleventh Circuit Declines to Extend to Summary Judgment Proceedings a Rule Requiring District Courts to Notify Pro Se Litigants, by Douglas Ankney
- BOP Cancels Union Rights for Prison Guards
- $4 Million Verdict Returned in Colorado Jail Suicide Case, by Chuck Sharman
- $100,000 Settlement Reached Between Imprisoned BOP Guard and Prisoners He Raped, by Chuck Sharman
- Fifth Circuit Dismisses Sex Abuse Claims Filed by Three Texas Prisoners Against Guard, by Chuck Sharman
- Nearly $528,000 Paid by Kansas Jail to Detainees Raped by Guards, by Chuck Sharman
- Two Re-Entry Non-Profit Leaders in Tennessee and Massachusetts Accused of Criminal Charges
- New York Jury Convicts Former Guard for Robert Brooks’ Taped Killing
- The Last Escaped Detainee from the New Orleans Jail Was Arrested in an Atlanta Crawlspace
- California Approves Higher Wage for Prisoner Firefighters (But Still Underpays)
- Former Prisoners’ Challenge to Virginia Constitution’s Felony Disenfranchisement Clause Allowed to Proceed, by Douglas Ankney
- $3.6 Million Paid by Minnesota County After Hemophiliac Jail Detainee Died from Brain Bleed, by Chuck Sharman
- Appeals Court Allows Illinois Prisoner’s Suit for Failure to Exhaust Administrative Remedies, by Douglas Ankney
- FCC Votes For Dramatic Hike to Prison Phone Call Rates, by Chuck Sharman
- News in Brief
More from Douglas Ankney:
- Pregnant Women Detained in Jail: The Hideous Story of In-Custody Births, May 1, 2026
- Idaho DOC Director Denies Verified Report of Rampant Sexual Abuse of Women Prisoners by Staff, May 1, 2026
- Illinois Jail Reprimanded for Denying Detainees Mail Based on Media Content, P.O. Box Return Address, Settles Detainees’ Suit with $111,825 Payment of Legal Fees, May 1, 2026
- Oklahoma Supreme Court: Jail Trust Cannot Withhold Requested Records under Law Enforcement Exemption of ORA, May 1, 2026
- Tenth Circuit Holds Prior California Child Pornography Conviction Does Not Trigger Federal Mandatory Minimum Because State Statute Encompasses Conduct Beyond Federal Definition Under Categorical Approach, April 1, 2026
- Kentucky Supreme Court Clarifies Parole Board May Delegate Final Revocation Hearings to Administrative Law Judges but Holds Due Process Requires Parolees Be Permitted to File Exceptions to ALJ Findings Before Board Renders a Final Revocation Decision, April 1, 2026
- New York Court of Appeals Holds Generic Physical Description Insufficient to Justify Pursuit in Mistaken Identity Case, and Suspect’s Flight Cannot Support Reasonable Suspicion Absent Evidence He Knew He Was Fleeing Law Enforcement, April 1, 2026
- Montana Supreme Court Holds Defendant’s Sentence Must Be Vacated Where District Court Premised Sentence on Defendant’s Exercise of Constitutional Rights to Jury Trial, Silence, and Against Self-Incrimination, April 1, 2026
- Fifth Circuit Holds Texas Sexual Assault of a Child Statute Sweeps More Broadly Than Federal SORNA Tier Offenses, March 1, 2026
- Delaware Supreme Court Announces Four-Part Plain Error Framework, Aligning Prejudice Standard With Federal Approach Requiring Reasonable Probability of Different Outcome, March 1, 2026
More from these topics:
- Oklahoma Supreme Court: Jail Trust Cannot Withhold Requested Records under Law Enforcement Exemption of ORA, May 1, 2026. Summary Judgment, Disclosure of Records, Public Records, Public Records Act, Statutory Construction/Interpretation.
- Nevada Non-Profit Founder Under Investigation for Misconduct, May 1, 2026. Staff-Prisoner Assault, Staff-Prisoner Harassment, Contractor Misconduct, Complaints, Restrictions, discrimination.
- Indiana DOC Found in Violation of State Public Records Act for Withholding Execution Drug Cost Information, May 1, 2026. Summary Judgment, First Amendment, Public Records Act, Interlocutory Appeals, Lethal Injection Method of Execution.
- Eighth Circuit Revives Lawsuit Over Iowa Jail Detainee’s Suicide, April 1, 2026. Summary Judgment, Failure to Protect (Wrongful Death), Failure to Treat (Mental Illness), Suicides.
- $1.5 Million Class-Action Settlement Reached in Texas Jail Over-Detention Case, April 1, 2026. Overdetention, 42 U.S. Code § 1983, civil action for deprivation of rights, Unlawful Detention, Monell Liability, Class Actions.
- Eighth Circuit Rules Iowa Prisoner’s Adverse Summary Judgment Is Not a “Strike”, March 1, 2026. Filing Fees (PLRA), Frivolous Litigation (PLRA), Summary Judgment, Failure to Treat (Mental Illness), Access To Courts.
- South Dakota Sobriety Program Participants Will No Longer Be Jailed for Non-Payment of Fees, March 1, 2026. Settlements, Class Certification, Fourteenth Amendment, rights, Unlawful Detention, Ability to Pay.
- Sixth Circuit Revives Michigan Prisoner’s Challenge to Guard Tackle That Broke His Foot, March 1, 2026. Evidentiary Ruling (Disciplinary Hearings), Guard Brutality/Beatings, Summary Judgment, Qualified Immunity, Wrongful Use of Force.
- Louisiana Prisoner Sustains Claim Against Prison Doctor for Allowing Assignment to “Field Duty” Despite Known Ankle Injury, March 1, 2026. Inability to Work, Skeletal Injury, Summary Judgment, Qualified Immunity, Deliberate Indifference.
- Massive $112 Million Jury Verdict for Detainees Held in New York Jail Past Release Date on ICE Detainers, Jan. 1, 2026. Fourth Amendment, rights, Detention - Generally, Unlawful Detention, Immunity - Sovereign/Municipal, Damages - Compensatory.

