Knopf v. Esposito

Background

The plaintiffs’ claim under 42 U.S.C. § 1983, a federal civil-rights statute, was dismissed on December 7, 2017. After dismissing that federal claim, the court declined to hear the plaintiffs’ state-law claims under the federal supplemental-jurisdiction statute. The court later denied the plaintiffs’ request to file a second amended complaint.

On February 25, 2020, the Second Circuit Court of Appeals reversed the dismissal of the § 1983 claim. Its mandate vacated the District Court’s judgment and post-judgment orders and sent the case back for further proceedings. The mandate issued on April 8, 2020.

The Parties’ Positions

After the federal claim was reinstated, the plaintiffs stated that they no longer wanted to litigate their state-law claims in federal court. The parties disagreed about whether those claims had been reinstated. On May 29, the plaintiffs asked for permission to file a second amended complaint that would omit the state-law claims and add support for their § 1983 claim.

Ruling

The court explained that Federal Rule of Civil Procedure 15 permits amendment of civil pleadings after a remand when the amendment is consistent with the appellate court’s decision. The court determined that the Second Circuit’s mandate had vacated the earlier denial of the plaintiffs’ request for leave to amend.

The court ordered that the plaintiffs may file a second amended complaint by June 15, 2020. It also ordered that the defendants’ time to answer the first amended complaint was extended until June 20, 2020. The order addressed amendment and filing deadlines; it did not decide the underlying § 1983 claim.