Laughlin v. Stuart
- Eric Tostrud
- 0:19-cv-02547
- U.S. District Court · District of Minnesota
- 14
In Laughlin v. Stuart, Judge Leung partly granted and partly denied plaintiffs’ amendment motion and County Defendants’ scheduling-motion request.
The order affected plaintiffs Malik Laughlin, Kenneth Lewis, and Michael Hari, as well as County Defendants James Stuart, Jonathon Evans, Lt. Sheila Larson, and Sgt. Carrie Wood. It also concerned Defendant Tessa Villegas and the proposed addition of Deputy Jesse Rasmussen.
What happened
In Malik Laughlin, Kenneth Lewis, and Michael Hari’s case against James Stuart and others, the plaintiffs asked to amend their civil-rights complaint after the deadline, and County Defendants asked to extend case deadlines. The plaintiffs wanted to remove some claims, add supporting facts, and add Hari’s claim against Deputy Jesse Rasmussen.
The court granted in part and denied in part the plaintiffs’ motion. It allowed them to add Hari’s Sixth Amendment claim against Rasmussen, remove the specified claims, and make specified organizational changes, but denied the proposed factual and other claim amendments. The court also granted in part and denied in part County Defendants’ motion, setting new deadlines tied to the filing of the second amended complaint.
Judge Tony N. Leung ruled that the parties had to show “good cause” under the scheduling rules to change expired deadlines. He found that the plaintiffs had not shown good cause for most proposed additions, while County Defendants had shown enough good cause to modify the schedule despite filing their motion later than would have been better.
The detailed version
- Laughlin v. Stuart · No. 0:19-cv-02547
- Eric Tostrud
- Feb. 23, 2021
Background
Malik Laughlin, Kenneth Lewis, and Michael Hari, who were proceeding without lawyers, brought claims under 42 U.S.C. § 1983 based on events at the Anoka County Jail. Their claims included allegations involving nutrition, access to lawyers and legal materials, attorney-client communications, searches, discovery, the law library, and disciplinary segregation.
The plaintiffs filed a motion for leave to amend their complaint after the scheduling-order deadline. They proposed removing claims concerning sexually abusive pat-down searches, punitive diet in segregation, and punitive disciplinary segregation; adding factual material learned during discovery; and adding Hari’s Sixth Amendment claim against Anoka County Deputy Jesse Rasmussen concerning the seizure of legal mail. County Defendants did not oppose the deletions or the Rasmussen claim but opposed most of the other proposed amendments.
County Defendants separately moved to modify the pretrial scheduling order. They sought additional time for discovery, nondispositive motions, dispositive motions, and trial preparation. Hari opposed that motion.
Legal standard and analysis
Because the deadline for amending pleadings had passed, the court applied Federal Rule of Civil Procedure 16(b), rather than relying only on Rule 15. Rule 16(b) allows a scheduling order to be modified only for “good cause” and with the judge’s consent. The court explained that good cause primarily depends on the moving party’s diligence in trying to meet the existing deadlines.
The court granted as unopposed the plaintiffs’ request to remove the specified claims and add Hari’s claim against Rasmussen. It also allowed specified organizational changes. But the plaintiffs had not explained why they could not meet the amendment deadline, and the court found that they had not shown good cause for adding factual material or the additional paragraphs and claims identified in the order. The court also found those factual additions largely unnecessary because the plaintiffs could use discovery evidence to support their existing claims.
The court found that County Defendants had shown good cause to modify the schedule, although they could have filed their motion earlier. The court considered delays associated with the parties’ filings and found that County Defendants had generally responded to discovery requests in good faith and complied with the rules and prior orders. The court also found that the plaintiffs would not be prejudiced by the schedule change.
Ruling
Judge Tony N. Leung granted in part and denied in part the plaintiffs’ motion for leave to amend. Plaintiffs were given 21 days to file an amended complaint adding Hari’s Sixth Amendment claim against Rasmussen, omitting the claims they proposed to delete, and making the organizational changes specifically permitted by the order. The motion was denied in all other respects.
Judge Leung also granted in part and denied in part County Defendants’ motion to modify the scheduling order. The modified deadlines provide 45 days for discovery and nondispositive motions after the second amended complaint is filed, 90 days for dispositive motions, and 120 days for the case to be trial ready. An amended pretrial scheduling order was to issue. The order did not decide the merits of the underlying civil-rights claims.
Read the full 14-page opinion on CourtListener, the free public archive maintained by the Free Law Project.