Tracey Rudder, Personal Representative for the Estate of Katie Nichole Primel v. Anessa Israel, et al.

Summary

The United States District Court for the Eastern District of Michigan adopted a magistrate judge’s recommended disposition, overruled objections by Advanced Correctional Healthcare, Inc., and accepted the plaintiff’s Sixth Amended Complaint. The court directed the magistrate judge to issue a report and recommendation on ACH’s pending motion to dismiss and allowed the remaining defendants until January 23, 2026, to answer or otherwise respond. The order concerns claims arising from the suicide of a pretrial detainee in the Genesee County Jail.

Holdings

1. When a party makes a specific objection to a portion of a magistrate judge's report and recommendation, the district court must review that portion de novo; general or insufficiently specific objections do not require independent review.
2. Leave to amend should be freely given when justice so requires, and the court properly allowed the plaintiff one final opportunity to amend because there was no evidence of bad faith, dilatory motive, lack of notice, or undue prejudice, and the repeated-amendment factor was not dispositive.

Questions Presented

1. Whether ACH's objections established that the magistrate judge erred in finding that amendment of the complaint would not be futile.
2. Whether the magistrate judge erroneously applied the factors governing leave to amend under Federal Rule of Civil Procedure 15(a)(2).
3. Whether the district court should adopt the magistrate judge's recommended disposition, accept the Sixth Amended Complaint, and direct further proceedings on ACH's motion to dismiss.

Disposition

other