Stovell v. James

Summary

The D.C. Circuit affirmed the district court’s dismissal of claims for fraud, breach of contract, and tortious interference under Federal Rule of Civil Procedure 12(b)(6). The court also upheld the denial of relief under Rule 60(b) and denial of leave to file a second amended complaint, and held that the appellant forfeited any challenge to the defamation ruling by failing to address it.

Holdings

1. The district court properly dismissed the fraud, breach-of-contract, and tortious-interference claims under Federal Rule of Civil Procedure 12(b)(6) because the complaint failed to state a claim upon which relief could be granted.
2. The appellant forfeited any challenge to the disposition of the defamation claims by failing to address that disposition in his appellate briefs.
3. The district court did not abuse its discretion by denying the appellant's motion for relief from judgment under Federal Rule of Civil Procedure 60(b).
4. The district court did not abuse its discretion by denying leave to file the second amended complaint because amendment would have been futile if the proposed claims could not survive a motion to dismiss.

Questions Presented

1. Whether the district court properly dismissed the fraud, breach-of-contract, and tortious-interference claims under Federal Rule of Civil Procedure 12(b)(6).
2. Whether the appellant forfeited any challenge to the disposition of the defamation claims by failing to address those claims in his appellate briefs.
3. Whether the district court abused its discretion by denying relief from judgment under Federal Rule of Civil Procedure 60(b).
4. Whether the district court abused its discretion by denying leave to file a second amended complaint.

Disposition

affirmed