Raysene Hall v. Antonio Apodaca, et al.

Summary

The United States District Court for the District of Arizona denied pro se Plaintiff Raysene Hall’s motion for leave to file a consolidated amended complaint. The Court held that the motion failed to comply with Local Rule of Civil Procedure 15.1, the Court’s prior orders, and the good-cause requirement under Federal Rule of Civil Procedure 16. The Court cautioned that any future attempt to amend must first establish good cause.

Holdings

1. A motion for leave to amend must comply with LRCiv. 15.1, including by attaching a proposed amended pleading that identifies deletions and additions and does not incorporate the prior pleading by reference. Hall's motion did not satisfy those requirements, providing an independent basis to deny leave.
2. Once a court-ordered deadline for amending pleadings has passed, a party must satisfy Federal Rule of Civil Procedure 16(b) by showing good cause to modify the scheduling order. Good cause requires demonstrating that the deadline could not be met despite the party's diligence, and Hall failed to make that showing.
3. Hall was not entitled to amend under the terms of the November 6, 2025 order because the proposed amended complaint did not track the claims authorized by that order and included a First Amendment retaliation claim that the order specifically excluded.

Questions Presented

1. Whether Hall's motion for leave to amend should be denied for failure to comply with Local Rule of Civil Procedure 15.1.
2. Whether, after the court-ordered amendment deadline had passed, Hall demonstrated good cause under Federal Rule of Civil Procedure 16(b) to modify the scheduling order and obtain leave to amend.
3. Whether Hall's proposed amended complaint complied with the restrictions imposed by the court's November 6, 2025 order.

Disposition

other