In Jefferson v. Amsted Rail Co., Kansas District Judge Kathryn H. Vratil, in a case where the defendant had filed five motions in recent months due to failure on the part of the pro se plaintiff to adhere to her discovery obligations, ruled that each of the five Ehrenhaus factors used to determine whether to order dismissal as a sanction “weighs in favor of dismissal” and dismissed the plaintiff’s claims with prejudice, adopting the recommendation of the magistrate judge.
