Christina Kish v. The School Board of Citrus County, Florida

Summary

The United States District Court for the Middle District of Florida addresses a pro se plaintiff’s motions to amend her ADA and Florida Civil Rights Act complaint and to obtain CM/ECF filing access. The court permits the amended complaint to be docketed, denies CM/ECF access, and authorizes electronic notification of filings by email.

Holdings

1. Because Plaintiff had not previously amended her complaint as a matter of course and no responsive pleading had been filed, she could exercise her Rule 15(a)(1) amendment right; the court therefore granted her motion to the extent necessary and directed the Clerk to docket the amended complaint.
2. The court denied Plaintiff's request for permission to file documents through CM/ECF because she did not show good cause or extenuating circumstances warranting an exception to the district's general restriction on pro se electronic filing.
3. Although Plaintiff was not permitted to file through CM/ECF, the court exercised its discretion to permit her to receive electronic notifications of filings by email.

Questions Presented

1. Whether Plaintiff could amend her complaint as a matter of course under Federal Rule of Civil Procedure 15(a)(1), notwithstanding that she filed a motion for leave under Rule 15(a)(2).
2. Whether a pro se litigant who has not shown good cause or extenuating circumstances should be permitted to file documents through CM/ECF.
3. Whether the court should permit Plaintiff to receive electronic notices of filing by email.

Disposition

other