Jidoefor v. Sherburne County

Background

Okwuchukwu E. Jidoefor brought this civil-rights action under 42 U.S.C. § 1983, alleging violations of his First, Sixth, and Fourteenth Amendment rights arising from his detention in the Sherburne County Jail. The court had issued a scheduling order setting January 30, 2023, as the deadline for motions to amend pleadings.

Jidoefor moved for permission to amend the amended complaint and to modify the scheduling order. He stated that he had been removed from the United States and transported to Nigeria on January 10, 2023, detained there for about a week, and then had difficulty finding legal materials and internet access. He said these circumstances delayed preparation of the proposed amended complaint.

The parties’ positions

Jidoefor sought an extension of the deadline for motions to amend, although the court could not determine any other specific extension date from his motion. He did not file a notice of motion, meet-and-confer statement, proposed order, proposed amended complaint, or redlined complaint showing the proposed changes.

The defendants argued that the motion should be denied because Jidoefor did not meet and confer with them, did not provide the required proposed amended complaint or redline, and did not state what extension of time he wanted.

Court’s analysis

The court explained that motions to amend pleadings and scheduling orders are non-dispositive motions subject to the District of Minnesota’s local rules. Those rules generally require a party to meet and confer with the opposing party before filing a motion and to file required supporting documents, including a proposed order. Local Rule 15.1 also requires a proposed amended pleading and a version showing the additions and deletions.

The court found that Jidoefor violated the meet-and-confer requirement. It also found that he failed to attach a proposed amended complaint or a redlined version. The court stated that a party’s status without a lawyer does not excuse compliance with the local rules. Finally, the court found that Jidoefor had not identified the date to which he wanted the amendment deadline extended.

Ruling

Judge Elizabeth Cowan Wright denied Jidoefor’s Motion for Leave to Amend the Amended Complaint and Modify the Scheduling Order without prejudice. Because the motion was denied on procedural grounds, the court made no finding about whether good cause existed under the federal rules and local rules to extend the scheduling order. The order also did not decide whether the proposed amendments would succeed on their merits.