C.A.C. v. Walton County School District - Case Dismissal
Summary
The U.S. District Court for the Middle District of Georgia dismissed the case of C.A.C. v. Walton County School District. The dismissal was due to the plaintiff's inability to proceed pro se on behalf of a minor child. The court denied the defendant's motion to dismiss as moot.
What changed
The U.S. District Court for the Middle District of Georgia, in Civil Action No. 3:25-cv-00184-TES-CHW, issued an order dismissing the case filed by C.A.C., a minor child, through her father Caleb Michael Clack, against the Walton County School District. The dismissal stems from the plaintiff's failure to secure legal representation, as parents cannot represent their minor children pro se in federal court. The court had previously granted an extension for the plaintiff to find counsel, warning of dismissal if this did not occur by January 30, 2026.
This ruling means the case is no longer proceeding. The defendant's motion to dismiss was denied as moot because the court initiated its own dismissal based on procedural grounds. Regulated entities, particularly educational institutions, should be aware of the strict requirements for legal representation in federal court, especially when minors are involved, and the consequences of failing to meet these procedural mandates.
What to do next
- Review internal procedures for handling cases involving minors to ensure proper legal representation is secured.
- Consult with legal counsel regarding pro se representation limitations in federal court for non-attorney parents.
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Jan. 30, 2026 Get Citation Alerts Download PDF Add Note
C.A.C., a minor child, by and through her father CALEB MICHAEL CLACK v. WALTON COUNTY SCHOOL DISTRICT
District Court, M.D. Georgia
- Citations: None known
- Docket Number: 3:25-cv-00184
Precedential Status: Unknown Status
Trial Court Document
IN THE UNITED STATES DISTRICT COURT
FOR THE MIDDLE DISTRICT OF GEORGIA
ATHENS DIVISION
C.A.C., a minor child, by and through her
father CALEB MICHAEL CLACK,
Plaintiff,
CIVIL ACTION NO.
v. 3:25-cv-00184-TES-CHW
WALTON COUNTY SCHOOL DISTRICT
Defendant.
ORDER DISMISSING CASE
Pro se Plaintiff Caleb Michael Clack filed a Complaint on November 21, 2025, on
behalf of his minor child C.A.C. [Doc. 1]. This Court ordered Plaintiff to show cause
why his case should not be dismissed for lack of proper representation since parents
can’t bring a pro se action on their child’s behalf in federal court. [Doc. 3]; see also Dixit
v. Fairnot, No. 7:19-cv-194 (WLS), 2023 WL 4188095, at *4 (M.D. Ga. June 26, 2023),
reconsideration denied, No. 7:19-cv-194 (WLS), 2023 WL 5075291 (M.D. Ga. July 14, 2023)
(“parents who are not attorneys may not bring a pro se action on their child’s behalf.”).
Plaintiff responded by asking the Court to appoint counsel, appoint a guardian ad
litem, or give Plaintiff more time to find an attorney. [Doc. 6]. The Court denied
Plaintiff’s motion to appoint counsel or a guardian ad litem, but it gave Plaintiff until
January 30, 2026, to find counsel, warning him that otherwise his case would be
dismissed. [Doc. 8]. The time for counsel to file an entry of appearance on behalf of
Plaintiff or his child has passed. Plaintiff cannot continue to bring this case pro se on
behalf of his minor child. Therefore, Plaintiff’s case is DISMISSED. See Fed. R. Civ. P.
41(b). Defendant Walton County School District’s Motion to Dismiss Complaint is
DENIED as moot.
SO ORDERED, this 30th day of January, 2026.
S/ Tilman E. Self, III
TILMAN E. SELF, III
UNITED STATES DISTRICT JUDGE
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