Before dismissing proceedings for an unrepresented litigant's refusal to proceed, a trial judge must squarely put to the litigant the consequences of that refusal, including costs liability and the nature of the dismissal (interlocutory or final). A court cannot act on a mere implication of discontinuance where the litigant is present and could be asked to clarify their position. The failure of a litigant to seek withdrawal of orders after they are made does not cure a prior denial of procedural fairness.
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8 of the 20 citing cases carry a classified treatment. How each court treated it is available to signed-in members.