Younger v. Gross and the Poulis Framework: Affirming Rule 41(b) Dismissals of Pro Se § 1983 Actions

I. Introduction

The Third Circuit’s nonprecedential per curiam opinion in Christopher Younger v. R. Gross, No. 25‑2765 (3d Cir. Dec. 19, 2025), revisits a recurring and sensitive issue in federal civil litigation: when is it proper for a district court to dismiss a pro se prisoner’s civil rights case with prejudice under Federal Rule of Civil Procedure 41(b) for failure to prosecute?

Although expressly designated “not precedential” under the Third Circuit’s Internal Operating Procedures, the decision is a detailed illustration of how the Poulis factors govern dismissals for failure to prosecute, even where the underlying claims have enough merit to survive summary judgment. It also underscores two important points:

The strong deference appellate courts give to district courts’ case‑management decisions under an abuse‑of‑discretion standard.
The limits on what a litigant can challenge on appeal when the final judgment is a Rule 41(b) dismissal, as clarified by R & C Oilfield Services LLC v. American Wind Transport Group LLC.

The case arises from an alleged episode of serious excessive force in the Allegheny County Jail (“ACJ”), brought under 42 U.S.C. § 1983 by Christopher Younger, initially as a pro se prisoner and later, at various points, with the assistance of different counsel. Despite the survival of most of his excessive force claims past summary judgment, the District Court ultimately dismissed the action with prejudice after years of delays, missed deadlines, and failures to comply with court orders. The Third Circuit summarily affirmed, holding that the District Court did not abuse its discretion.

II. Factual and Procedural Background

A. The Underlying § 1983 Claims

In 2020, Younger filed a pro se civil rights complaint under 42 U.S.C. § 1983 against several ACJ officials: Corrections Officer R. Gross, Captain D. Edwards, Sergeant A. Tucker, and Corrections Officer J. Holt. He alleged that:

After he requested access to the law library, several officers beat him and tackled him to the ground despite his non-resistance.
One officer repeatedly deployed a taser against him.
He was then placed in a restraint chair for approximately nine hours without relief breaks.

These allegations implicate classic excessive force principles under the Eighth or Fourteenth Amendments (depending on his custodial status), as enforced through § 1983.

B. Early Merits Rulings: Partial Summary Judgment

In March 2023, defendants moved for summary judgment. The District Court (a Magistrate Judge presiding with the parties’ consent under 28 U.S.C. § 636(c)(1)):

Granted summary judgment in favor of certain defendants on Younger's First Amendment retaliation claims.
Denied summary judgment on the “bulk” of the excessive force claims.

Thus, Younger's core excessive force claims were deemed sufficiently meritorious to proceed toward trial.

C. Post‑Summary Judgment: Mediation Efforts and Communication Failures

After Younger was no longer incarcerated, the court attempted to manage and potentially resolve the case through mediation:

The court invited Younger to participate in its Pro Se Prisoner Mediation Program, directing him to respond by April 14, 2023. The order, mailed to his address of record, was returned as undeliverable, and then resent.
On May 2, 2023, a further order directed Younger to indicate whether he would participate in mediation, noted that he had not communicated with the court since August 2022, and warned that failure to respond by May 16 could result in dismissal for failure to prosecute.
On May 24, Younger filed a change‑of‑address notice and a motion to appoint counsel.
On May 30, 2023, the court again directed Younger to inform it by June 14 whether he wished to participate in mediation. That mailing, sent to his updated address, was returned as undeliverable on June 23.

On June 29, 2023, the District Court administratively closed the case, stating that it would be reopened no later than August 1, 2023 if Younger:

Provided a deliverable address, and
Supplied a current phone number.

The order expressly warned that failure to respond by August 1 would result in dismissal for failure to prosecute. Younger did not respond, and the court dismissed the case with prejudice on August 23, 2023 under Rule 41(b).

D. Reopening the Case and Further Delays

In November 2023, Younger obtained counsel and moved to reopen the case. The court granted the motion several months later. Key subsequent events included:

February 2024: A telephone conference was held; mediation was set for April 3, 2024.
March 28, 2024: Younger's attorney moved to withdraw; mediation was postponed. The motion to withdraw was granted.
The court ordered Younger to advise by April 22, 2024 whether he would retain new counsel or wanted appointed counsel for mediation.
When he did not respond, the court extended the deadline to June 7, 2024, warning that failure to respond again could lead to dismissal for failure to prosecute.
May 9, 2024: Younger filed a “motion for a speedy trial,” which the court:
- Denied, and
- Construed as an indication that he did not wish to retain or receive appointed counsel (at least for mediation purposes).

In July 2024, the court scheduled trial for December 9, 2024. However, in August 2024, Younger changed course and moved for appointment of counsel. The court granted that motion, postponed the trial date, and temporarily closed the case to allow time to identify counsel.

E. Court‑Appointed Counsel and Settlement Efforts

In February 2025, court‑appointed counsel entered an appearance for Younger. On March 5, 2025, a telephone conference occurred:

Court‑appointed counsel reported an inability to contact Younger at the address and phone number of record.
Subsequently, counsel reported that he had established contact with Younger, and a settlement conference was set for June 27, 2025.

Then the representation picture changed again:

June 12, 2025: A new attorney entered a notice of appearance on Younger's behalf.
June 17, 2025: At a status conference, court‑appointed counsel made an oral motion to withdraw.

At that same June 17 conference, the court instructed Younger to submit a written itemization and settlement demand to defense counsel by June 23, 2025.

On June 26, 2025 — after the deadline — Younger himself (acting pro se) filed a motion to stay, asserting that the most recent attorney was merely “stand‑by” counsel. This raised confusion regarding his representation status. The court:

Postponed the settlement conference, and
Ordered Younger to file, by July 11, 2025, either:
- a status report clarifying his representation, or
- a motion formally discharging his counsel.

After Younger missed that deadline, the court reissued its order. On July 15, 2025, Younger filed a motion to withdraw his third counsel, which the court granted on July 16, 2025. A telephonic status conference was scheduled for July 29, 2025.

F. Missed Status Conference and Show‑Cause Order

Younger failed to appear for the July 29 status conference. The District Court then issued an order directing him to show cause by August 6, 2025 why the case should not be dismissed for failure to prosecute.

On August 7, 2025, Younger's third counsel re‑filed a notice of appearance and submitted:

A response to the show‑cause order, and
A motion for an extension of time to respond to the order.

In the response, Younger contended that:

He was unaware of the July 29 conference, and
He had been mourning his mother's death.

The District Court rejected these justifications. It emphasized that:

The scheduling conference order had been mailed to Younger's address of record and was not returned as undeliverable.
In his earlier stay petition, Younger had stated that he had “criminal cases that need to be first on the list” for his time, undermining claims that his failure was inadvertent or solely due to grief.

The court concluded that Younger was willfully failing to prosecute his civil case and dismissed it with prejudice under Rule 41(b).

G. Appeal and Motions in the Court of Appeals

Younger filed a timely appeal. On appeal:

Younger moved for appointment of counsel.
Appellees moved for summary affirmance under Third Circuit L.A.R. 27.4 and I.O.P. 10.6, asserting that the appeal presented no substantial question.
Younger did not respond to the summary affirmance motion.

The Third Circuit exercised jurisdiction under 28 U.S.C. § 1291, reviewed the Rule 41(b) dismissal for abuse of discretion, and ultimately:

Granted the appellees’ motion for summary affirmance,
Summarily affirmed the Rule 41(b) dismissal with prejudice, and
Denied Younger's motion for appointment of counsel on appeal.

III. Summary of the Opinion

The Court of Appeals’ reasoning can be distilled into several key points:

Jurisdiction and Standard of Review: The court confirmed jurisdiction under 28 U.S.C. § 1291 and applied the abuse‑of‑discretion standard for reviewing a dismissal for failure to prosecute, citing Briscoe v. Klaus, 538 F.3d 252 (3d Cir. 2008).
Scope of Review Limited to the Rule 41(b) Dismissal: Relying on R & C Oilfield Services LLC v. American Wind Transport Group LLC, 45 F.4th 655 (3d Cir. 2022), the court stated that, where the final order on appeal is a dismissal for failure to prosecute, it does not review earlier orders granting partial summary judgment or dismissing certain claims.
Rule 41(b) and the Poulis Framework: The court reiterated that a district court may sua sponte dismiss for failure to prosecute under Rule 41(b), but must first weigh the six Poulis factors: personal responsibility, prejudice, history of dilatoriness, willfulness/bad faith, alternative sanctions, and the merits.
Application of Poulis: The District Court had found that:
- Younger’s claims were meritorious enough to survive summary judgment (favoring him on the “merits” factor), but
- The other five factors weighed against him and favored dismissal.
The Third Circuit held that this assessment was thorough and within the court’s discretion.
No Abuse of Discretion: Given the length of the case (over five years), repeated missed deadlines, failure to keep the court informed of his address and contact information, missed conferences, and evidence of willful de‑prioritization of the case, the appellate court concluded that the drastic sanction of dismissal with prejudice was justified.
Summary Affirmance and Denial of Counsel: Because the appeal presented no substantial question under L.A.R. 27.4 and I.O.P. 10.6, the court summarily affirmed and denied the motion for appointment of counsel.

IV. Precedents and Authorities Cited

A. Federal Rule of Civil Procedure 41(b)

Rule 41(b) provides that a defendant may move to dismiss an action for a plaintiff’s:

Failure to prosecute, or
Failure to comply with the Federal Rules of Civil Procedure or a court order.

Unless the dismissal order states otherwise, a dismissal under Rule 41(b) operates as an adjudication on the merits — i.e., it is “with prejudice.”

The Third Circuit has long recognized that a district court may invoke Rule 41(b) sua sponte (on its own initiative), even without a defense motion, when a plaintiff abandons prosecution or repeatedly disregards court orders. In this case, the District Court did just that, after a series of warnings and opportunities to cure.

B. Poulis v. State Farm Fire & Casualty Co., 747 F.2d 863 (3d Cir. 1984)

Poulis is the foundational Third Circuit decision setting out the six factors that must be considered before a case is dismissed for failure to prosecute or comply with orders:

Extent of the party’s personal responsibility;
Prejudice to the adversary caused by the failure to meet deadlines or comply with orders;
History of dilatoriness (chronic lateness or neglect);
Whether the conduct was willful or in bad faith;
Effectiveness of sanctions other than dismissal, including an analysis of alternatives; and
Meritoriousness of the claim or defense.

Poulis emphasizes that:

Dismissal is a “drastic” sanction that should be reserved for “extreme” cases, and
No single factor is outcome‑determinative; courts must balance them as a whole.

In Younger, the appellate court explicitly applied this framework, reviewing the District Court’s assessment of each factor, and confirmed that a dismissal can be proper even when one factor (here, the merits) favors the plaintiff.

C. Briscoe v. Klaus, 538 F.3d 252 (3d Cir. 2008)

Briscoe is a key Third Circuit case that:

Reaffirms that dismissal with prejudice is an “extreme” sanction, especially serious in the context of prisoner civil rights litigation.
Clarifies that courts must carefully apply the Poulis factors before dismissing, and explains that not all factors need to support dismissal to make it appropriate.

Citing Briscoe, the Younger panel reiterates two important principles:

“Dismissal with prejudice is a drastic measure” that should not be imposed lightly, and
“No single Poulis factor is determinative” and not all factors must favor dismissal for it to be upheld.

By invoking Briscoe, the court signals continuity: despite the gravity of erasing a pro se litigant’s case, repeated and willful noncompliance over years can justify that outcome.

D. R & C Oilfield Services LLC v. American Wind Transport Group LLC, 45 F.4th 655 (3d Cir. 2022)

R & C Oilfield addresses what appellate orders are reviewable when the final judgment is a dismissal for failure to prosecute. The Third Circuit in Younger cites R & C Oilfield for the principle that:

Where, as here, the final order being appealed is a dismissal for failure to prosecute, we do not review the District Court’s earlier orders dismissing or granting summary judgment as to several of plaintiff’s claims.

This reflects a limitation on the general “merger doctrine,” under which prior interlocutory orders typically merge into the final judgment and become reviewable. In R & C Oilfield, the court held that when a plaintiff’s case ends due to a sanction dismissal for failure to prosecute (rather than a merits ruling), appellate review is focused on the propriety of the sanction itself, not on underlying merits determinations.

Thus, in Younger, the court considers only whether the Rule 41(b) dismissal was an abuse of discretion; it declines to reexamine the earlier summary judgment rulings on the First Amendment retaliation claims or other prior merits determinations.

V. The Court’s Legal Reasoning

A. Jurisdiction, Standard of Review, and Summary Action

The Third Circuit exercised jurisdiction under 28 U.S.C. § 1291 over the final judgment dismissing the action. Because the dismissal was for failure to prosecute, the standard of review is abuse of discretion. This is a highly deferential standard:

The appellate court asks whether the district judge’s decision was within the range of permissible choices, given the facts and applicable law.
Even if the appellate court might have chosen a different sanction in the first instance, it does not substitute its judgment unless the lower court’s decision was unreasonable or based on a clearly erroneous assessment of the record.

The court also applied its local rules permitting summary action:

L.A.R. 27.4 and I.O.P. 10.6 authorize summary affirmance when an appeal does not raise a “substantial question.”
Here, after reviewing the record and the District Court’s reasoning, the panel concluded that the appeal was insubstantial — essentially that no reasonable jurist would find an abuse of discretion.

Consequently, the court granted appellees’ motion for summary affirmance and denied Younger's motion for appointed appellate counsel.

B. Application of Poulis and Rule 41(b)

The controlling issue was whether the District Court abused its discretion in dismissing the case with prejudice under Rule 41(b). The Third Circuit reviewed how the District Court applied the Poulis factors.

1. Extent of the Party’s Personal Responsibility

The District Court found — and the Third Circuit agreed — that Younger bore personal responsibility for the failures at issue. Reasons included:

Failure over long periods to communicate with the court (no contact between August 2022 and late May 2023).
Failure to provide and maintain a deliverable mailing address and a current phone number, resulting in returned mail and inability to contact him.
Failure to respond to orders directing him to:
- Indicate whether he would participate in mediation,
- Clarify whether he intended to retain or accept appointed counsel, and
- Provide a settlement demand by a specific date.
Failure to appear for the July 29, 2025 status conference after notice was sent to his address of record.

Although the case involved multiple attorneys, much of the delay and noncooperation occurred when Younger was representing himself or making decisions about counsel. The court therefore treated these failings as directly attributable to him.

2. Prejudice to the Adversary

The District Court concluded that further delay would prejudice the defendants, and the Third Circuit agreed. The case had been pending for over five years. Courts often recognize that lengthy delays can prejudice defendants because:

Witness memories fade.
Institutional records can be lost or become harder to locate.
Public officials (like jail officers) may transfer, retire, or otherwise become unavailable.
Defendants repeatedly must expend resources preparing for proceedings that are frequently postponed or derailed.

In that context, yet more delays, particularly when attributable to the plaintiff’s own actions, were deemed prejudicial to the defendants’ ability to defend the case effectively.

3. History of Dilatoriness

A “history of dilatoriness” means not just a single missed deadline, but a pattern of delay and noncompliance. The record reflected numerous such episodes:

Failure to communicate with the court for many months at a time.
Failure to respond to multiple court orders by the stated deadlines, even after extensions.
Returned mail due to Younger's failure to keep his address current.
Last‑minute changes of position regarding whether he would proceed with counsel or pro se, complicating settlement scheduling and trial preparation.
Non‑appearance at the July 29 status conference, even after the court had repeatedly emphasized the need for compliance.

This consistent pattern over several years strongly supported the conclusion that Younger had a history of delay.

4. Willfulness or Bad Faith

The District Court concluded that Younger's conduct was willful, rather than accidental or purely negligent. The Third Circuit agreed, highlighting:

Repeated missed deadlines despite explicit warnings that failure to comply could result in dismissal.
Younger's own statement in his stay motion that he had “criminal cases that need to be first on the list” — suggesting a deliberate decision to de‑prioritize this civil case.

In response to the show‑cause order, Younger argued that he did not know of the scheduled conference and that he had been grieving his mother's death. The District Court was unpersuaded, because:

The notice of the conference was sent to his address of record and not returned as undeliverable.
His own prior statement about prioritizing other matters weighed against the idea that his absence was inadvertent or solely attributable to bereavement.

On this record, the court characterized the conduct as willful noncompliance rather than excusable neglect.

5. Effectiveness of Alternative Sanctions

Before dismissing, a district court must consider whether less severe sanctions could remedy the problem. Examples might include:

Monetary penalties,
Explicit warnings,
Preclusion of certain evidence or issues, or
Imposition of additional conditions on further litigation.

Here, although the opinion does not detail every alternative the District Court considered, it indicates that:

The court had repeatedly given Younger additional chances, including:
- Extending deadlines,
- Re‑sending orders when mail was returned,
- Administrative closure with clear conditions for reopening, and
- Reopening the case after an earlier dismissal, once new counsel appeared.
Younger was proceeding in forma pauperis, so monetary sanctions were not realistically enforceable or effective.

Given these facts, the District Court determined that lesser sanctions had been tried or were unlikely to succeed, and that dismissal was the only effective remedy. The Third Circuit found no fault with this conclusion.

6. Meritoriousness of the Claim

The “meritoriousness” factor asks whether the claim appears to have some legal and factual basis — not whether the plaintiff is certain to win. Here, the District Court acknowledged that Younger's excessive force claims were strong enough to survive summary judgment, which weighs in his favor under this factor.

However, as Briscoe and Poulis make clear:

No single factor controls, and
Dismissal may still be proper even if the claims are potentially meritorious, when the other factors decisively support dismissal.

The Third Circuit explicitly notes that the District Court found this factor in Younger's favor, but that the other five factors weighed against him. This was sufficient to uphold the dismissal.

C. No Abuse of Discretion

Weighing all six Poulis factors, the Third Circuit concluded that the District Court acted well within its discretion:

Younger's persistent noncompliance was personally attributable to him,
The defendants faced real prejudice after more than five years of litigation and frequent delay,
There was a clear pattern of dilatoriness,
The conduct was deemed willful, not accidental, and
Alternative sanctions had been considered and found ineffective or impracticable.

Accordingly, the appellate court held that the District Court did not abuse its discretion in dismissing the action with prejudice. It therefore granted summary affirmance and denied appellate counsel.

VI. Simplifying Key Legal Concepts

A. “Failure to Prosecute” and Rule 41(b)

“Failure to prosecute” means that the plaintiff is not actively pursuing the case. Typical examples include:

Not responding to court orders,
Not showing up for scheduled hearings or conferences,
Allowing long periods to pass with no filings or activity, or
Failing to provide necessary information, such as contact details, to move the case forward.

Rule 41(b) allows a court to dismiss a case if this happens, either at the defendant’s request or on the court’s own initiative (sua sponte). Unless the court states otherwise, such a dismissal is “with prejudice,” meaning the plaintiff cannot simply refile the same case.

B. “With Prejudice” vs. “Without Prejudice”

With prejudice: The case is permanently ended on the merits as to that claim or action. The plaintiff cannot start the same lawsuit again.
Without prejudice: The plaintiff may refile the case, subject to applicable statutes of limitation and other procedural requirements.

In Younger, the dismissal was explicitly “with prejudice,” reflecting the court’s view that, after years of repeated noncompliance, another chance would not serve the interests of justice or efficient administration.

C. “Abuse of Discretion” Standard

When a decision is reviewed for “abuse of discretion,” the appellate court is not deciding the matter anew. Instead, it asks whether the district court:

Made a decision that was reasonable in light of the facts and law,
Considered the relevant factors (such as the Poulis factors), and
Avoided clear legal errors or clearly erroneous factual findings.

If there is a reasonable range of permissible decisions, the appellate court will not substitute its judgment, even if it might have chosen a different option.

D. “Pro Se” and “In Forma Pauperis”

Pro se: A litigant acts pro se when representing himself or herself without a lawyer.
In forma pauperis: Latin for “in the manner of a pauper.” A litigant granted this status is allowed to proceed without paying typical court fees, based on indigence.

While courts often give pro se and in forma pauperis litigants some procedural leeway, those litigants are still required to comply with court orders and rules. Younger demonstrates that repeated failures to do so can result in dismissal, just as for represented parties.

E. “Summary Affirmance” and “Substantial Question”

The Third Circuit can affirm a district court judgment without full briefing and oral argument through “summary action” when the appeal does not present a “substantial question.” A “substantial question” is one on which reasonable jurists could disagree, or which requires more detailed analysis.

In Younger, the court found that the record and law clearly supported the District Court’s decision, so a full, conventional appeal was unnecessary.

F. “Show Cause Order”

A show‑cause order directs a party to explain why a certain action (such as dismissal or sanctions) should not be taken. It typically:

Identifies the potential sanction, and
Gives the party a deadline to respond with reasons or evidence.

In Younger, the show‑cause order warned that the case could be dismissed for failure to prosecute unless Younger provided a satisfactory justification for his non‑appearance at the status conference. His response — invoking lack of notice and his mother’s death — was found inadequate in light of the record.

VII. Impact and Implications

A. Implications for Pro Se Prisoner and Former‑Prisoner Litigants

Younger underscores that:

Even meritorious civil rights claims can be forfeited if the plaintiff persistently fails to comply with court orders.
Pro se status does not excuse repeated noncompliance, especially after extended warnings and multiple opportunities to correct course.
Former prisoners who are released must be especially diligent in:
- Updating their mailing address and telephone number, and
- Monitoring mail from the court and opposing counsel.

For incarcerated or recently released litigants, the case is a practical reminder: staying in contact with the court and responding promptly to orders is essential. Even where the underlying allegations are serious (excessive force and prolonged restraint), procedural neglect can lead to irreversible dismissal.

B. Case Management and Deference to District Courts

The opinion illustrates the deference that appellate courts afford to trial judges in managing their dockets:

District judges are responsible for ensuring that cases proceed efficiently and fairly.
When a plaintiff repeatedly delays proceedings and disregards orders, dismissal can be necessary to protect the integrity of the judicial process.
The Third Circuit’s summary affirmance signals that, when a thorough Poulis analysis is conducted and well‑supported by the record, district courts’ dismissal decisions will rarely be disturbed.

This reinforces incentives for district courts to:

Give clear warnings and opportunities to comply,
Create a record that addresses each Poulis factor, and
Explain why lesser sanctions would be ineffective.

C. Limits on Appellate Review of Underlying Merits

By invoking R & C Oilfield, the opinion reminds litigants that:

When a case ends through a Rule 41(b) failure‑to‑prosecute dismissal, the appeal focuses on the propriety of that sanction, not on prior summary judgment orders or other rulings on the merits.
A plaintiff cannot use an appeal from a sanctions‑based dismissal to reopen previously resolved substantive claims.

In practice, this means that plaintiffs must:

Vigilantly litigate their cases and obey court orders once some claims survive summary judgment, and
Understand that neglecting the case may ultimately shield earlier adverse rulings from substantive appellate review.

D. Counsel Appointment and Plaintiff Responsibility

The case also sheds light on the role of appointed and retained counsel:

Younger's case involved multiple shifts between pro se status, retained counsel, and court‑appointed counsel.
Despite these changes, the District Court and Third Circuit treated the persistent failures to communicate and comply as Younger's responsibility.

This highlights two points:

Appointment of counsel is not a panacea; if a client is unresponsive or refuses to cooperate, counsel’s presence cannot prevent dismissal.
Repeated retention and discharge of counsel can itself reflect or exacerbate a pattern of dilatoriness.

On appeal, the denial of appointed counsel further reflects the court’s view that the legal issues were straightforward under existing law and did not warrant the resources of appointed appellate counsel.

E. Settlement, Mediation, and Litigant Obligations

The case demonstrates how procedural noncompliance can derail alternative dispute resolution efforts:

The District Court repeatedly attempted to resolve the matter through a mediation program and later through a settlement conference.
Younger's failure to respond to mediation invitations, confusion about his representation status, and late settlement demand contributed to ongoing delays.

For litigants, this reinforces that:

Participation in court‑ordered mediation and settlement processes is not optional if ordered.
Failing to meet obligations related to settlement (such as providing a demand) can be considered part of a pattern of failure to prosecute.

VIII. Conclusion

Younger v. Gross does not break new doctrinal ground, and the court itself labels the disposition “not precedential.” Yet, it is a significant and instructive application of familiar principles:

The Poulis six‑factor test governing dismissals for failure to prosecute,
The high deference owed to district courts under the abuse‑of‑discretion standard, and
The limitation on appellate review of underlying merits rulings when the final judgment is a Rule 41(b) dismissal, as clarified in R & C Oilfield.

The opinion’s core message is that federal courts will protect their dockets and the interests of defendants from prolonged, willful neglect — even when the plaintiff is pro se or indigent, and even when the underlying claims appear facially meritorious. Multiple warnings, repeated extensions, administrative closure and reopening, and appointment of counsel do not guarantee indefinite leniency when a litigant repeatedly fails to fulfill basic obligations to prosecute the case.

For practitioners, pro se litigants, and courts managing heavy civil rights dockets, Younger stands as a clear — if nonbinding — illustration of when dismissal with prejudice under Rule 41(b) will be affirmed: where the plaintiff bears personal responsibility for chronic delay, the defendants are prejudiced by continued postponements, the conduct is willful, lesser sanctions have failed or would be futile, and only the merits of the claims weigh in the plaintiff’s favor.