Glover v. Rodriguez

Background

Wilbert Glover sued Richard Rodriguez, Tanner Hendrikson, Ross Alberts, Brad Lindberg, Brad Trelstad, and Ramsey County. He alleged that he was arrested and booked on false charges without evidence and was assaulted by officers at the Ramsey County Adult Detention Center. His complaint asserted claims under 42 U.S.C. § 1983 for deprivation of civil rights and under 42 U.S.C. § 1981 for discrimination under the law. The complaint sought compensatory, nominal, and punitive damages.

Glover filed a motion titled “Motions to Amend to Add Punitive Damage.” His filing referred to constitutional-rights injuries, an alleged violation of Ramsey County policies, and physical, mental, and emotional conditions. He attached prescription information and responses to health questionnaires.

Legal standard

Federal Rule of Civil Procedure 15 generally allows a party to amend a pleading with the court’s permission, and courts should freely allow amendments when justice requires. But amendment may be denied for reasons including undue delay, prejudice, or failure to comply with procedural requirements. Because Glover filed his motion after the scheduling-order deadline, the court also considered Rule 16(b)(4), which requires good cause to change a scheduling order. The court explained that good cause primarily depends on the moving party’s diligence.

Court’s analysis and ruling

The court held that Glover’s motion was moot because his original complaint already requested punitive damages. The court therefore denied the motion to amend.

The court also stated that it would deny the motion for additional reasons even if it were not moot. Glover filed the motion on January 20, 2023, after the December 1, 2022 deadline for motions to amend. He did not explain why he missed the deadline or show good cause for changing it. In addition, he did not comply with District of Minnesota Local Rule 15.1(b), which required him to provide both a copy of the proposed amended pleading and a marked version showing the proposed changes.

Disposition

The court denied Glover’s “Motions to Amend to Add Punitive Damage.” It ordered that the exhibits filed with the motion remain sealed permanently and stated that prior consistent orders remained in full force and effect. The order did not decide whether Glover would ultimately be entitled to punitive damages; it denied the requested amendment because punitive damages were already sought and because the motion was untimely and procedurally deficient.