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S.D.N.Y.Procedural orderFiled Mar. 16, 2020

Delacruz v. Bed Bath & Beyond Inc.

Judge
Analisa Torres
Docket
1:19-cv-09852
Court
U.S. District Court · Southern District of New York
Pages
1
Civil ProcedureMotion to Dismiss
In one sentence

In Delacruz v. Bed Bath & Beyond, Judge Torres denied Bed Bath & Beyond’s motion to dismiss the original complaint as moot after an amended complaint was filed.

Who this affects

Emmanuel Delacruz and Bed Bath & Beyond, Inc.; the order addressed only the defendant’s motion directed at the original complaint.

What happened

In Delacruz v. Bed Bath & Beyond Inc., the defendant asked the court to dismiss the original complaint for failing to state a claim.

Before the court ruled on that request, Emmanuel Delacruz filed an amended complaint under Rule 15(a)(1)(B) of the Federal Rules of Civil Procedure. The amended complaint replaced the original one, so the motion targeting the original complaint no longer addressed the operative pleading.

Judge Analisa Torres denied the motion to dismiss as moot and directed the Clerk of Court to terminate the motion. The order did not decide whether the amended complaint stated a valid claim.

The detailed version

For law students, journalists, and other readers who want the full reasoning

Case
Delacruz v. Bed Bath & Beyond Inc. · No. 1:19-cv-09852
Judge
Analisa Torres
Date
Mar. 16, 2020

Background

On February 26, 2020, Bed Bath & Beyond, Inc. moved to dismiss Emmanuel Delacruz’s original complaint for failure to state a claim. On March 11, 2020, Delacruz filed an amended complaint under Rule 15(a)(1)(B) of the Federal Rules of Civil Procedure.

Reasoning

An amended complaint supersedes, or replaces, the original complaint. Because the motion to dismiss was directed at the original complaint, the filing of the amended complaint made that motion moot, meaning the court no longer needed to decide it as presented.

Ruling

Judge Analisa Torres denied the defendant’s motion to dismiss the original complaint as moot. The Clerk of Court was directed to terminate the motion at ECF No. 27. The order did not rule on the sufficiency of the amended complaint or otherwise decide the underlying claims.

The authoritative version

Read the full 1-page opinion on CourtListener, the free public archive maintained by the Free Law Project.

Open opinion PDF →
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