Mark Clayton v. William Young, Tom Lawless, and Paige Dennis

Summary

The United States District Court for the Middle District of Tennessee denied the plaintiff's motion for leave to file a Fourth Amended Complaint and two motions seeking reconsideration. The court held that the proposed slander claim against Assistant District Attorney Brian Ewald was barred by Tennessee's six-month statute of limitations and did not relate back under Federal Rule of Civil Procedure 15(c). The court also concluded that certain prosecutorial conduct would be protected by absolute prosecutorial immunity and that no prior order dismissing John Doe defendants existed.

Holdings

1. Leave to amend was denied because the proposed slander claim was time-barred and could not relate back under Rule 15(c).
2. The plaintiff could not invoke the discovery rule to avoid the statute of limitations for the proposed claims.
3. The motions for reconsideration were denied because there was no prior order dismissing John Doe or Davidson County district attorney defendants for the court to reconsider.
4. To the extent the proposed claims were based on conduct Ewald undertook in his prosecutorial capacity, he would be entitled to absolute prosecutorial immunity.

Questions Presented

1. Whether leave to amend should be denied as futile because the proposed slander claim against Brian Ewald was barred by Tennessee's six-month statute of limitations and did not relate back under Federal Rule of Civil Procedure 15(c).
2. Whether the plaintiff could rely on the discovery rule to avoid the statute of limitations for the proposed slander and conspiracy claims.
3. Whether the plaintiff's Rule 54(b) motions for reconsideration should be granted when no order had dismissed any John Doe or Davidson County district attorney defendants.
4. Whether prosecutorial immunity would independently bar claims based on Ewald's prosecutorial conduct.

Disposition

other