Mejia v. Peach Skin Sheets L.L.C.

Background

Richard Mejia, through counsel, filed a letter-motion seeking two forms of relief. First, he asked to pause briefing on Peach Skin Sheets LLC’s motion for summary judgment until fact discovery ended on May 22, 2023. He argued that discovery was still outstanding, including information about the development and design of the defendant’s website, communications concerning equal accessibility, and testimony from a designated company witness about efforts to comply with the Americans with Disabilities Act and the Web Content Accessibility Guidelines 2.1.

Mejia stated that the defendant had not provided discovery responses, except for the name of one unidentified person who might have discoverable information. He also requested three additional days to file an opposition if the court did not pause the summary-judgment briefing.

Second, Mejia requested permission under Federal Rule of Civil Procedure 15(a)(2) to file an amended complaint. He argued that this would be his first amended complaint, that the amendment would not be futile, and that there was no bad faith, undue delay, or undue prejudice to Peach Skin Sheets LLC. He also referred to a Second Circuit decision issued after the original complaint was filed.

Court’s Rulings

The court denied the motion for leave to amend the complaint without prejudice to renewal by formal motion. This means the order did not bar Mejia from renewing the request, but the court did not grant permission to amend through the letter-motion.

The court also denied the motion to stay summary-judgment briefing without prejudice to Mejia making a proper showing that consideration of summary judgment would be premature. The court specified that the showing should be made through a statement under Federal Rule of Civil Procedure 56(d), filed in opposition to the summary-judgment motion.

The order did not decide whether summary judgment should be granted, whether the website was accessible, or the merits of Mejia’s underlying claims. It ruled only on the requested amendment and briefing-related relief.