7th Circuit Finds Pro Se Filing Doesn’t Excuse Error Of Voluntary Dismissal

(January 10, 2019, 11:44 AM EST) -- CHICAGO — An employee who brought pro se claims of race bias and retaliation, voluntarily dismissed them and then later tried to refile the claims failed to show that an “exceptional circumstance” existed that would allow his untimely case to proceed, a Seventh Circuit U.S. Court of Appeals panel ruled Dec. 28 (Christopher W. Fillmore v. Indiana Bell Telephone Company, Incorporated, et al., No. 18-2355, 7th Cir., 2018 U.S. App. LEXIS 36695)....

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