Background
Nichole McGill filed an action in the United States District Court for the Eastern District of Virginia alleging that Loudoun County Transit failed to accommodate her health issues in violation of the Americans with Disabilities Act and Virginia law. The district court dismissed the action without prejudice because McGill failed to comply with discovery obligations and orders directing her to respond to the defendant’s discovery requests.
The court’s reasoning
The court reviewed the record and found no reversible error by the district court. It cited United States versus Shaffer Equipment Company to note that factors for dismissal as a sanction include the degree of the wrongdoer’s culpability and the prejudice to the judicial process and the administration of justice.
What it means going forward
The decision reinforces that federal courts may dismiss civil rights actions without prejudice when plaintiffs fail to comply with discovery orders, citing the need to protect the judicial process from prejudice.