Sam Bowling and Ryan Owens v. Metropolitan Government of Nashville and Davidson County, et al.

Summary

The court denies Sam Bowling’s post-judgment motion for leave to file an amended complaint and his request for a hearing. Construing the motion under Federal Rule of Civil Procedure 59(e), the court concludes that none of the grounds for altering the judgment applies and directs the Clerk to return the proposed amended complaint so Bowling may file a new action.

Holdings

1. A motion for leave to amend filed after entry of judgment, even when styled under Rule 15(a)(2), is properly treated as a motion to alter or amend the judgment under Rule 59(e) when it seeks to reopen the closed case.
2. Bowling did not establish a clear error of law, newly discovered evidence, an intervening change in controlling law, or a need to prevent manifest injustice warranting alteration or reopening of the judgment.
3. Bowling was not entitled to a hearing before the court ruled on the post-judgment motions.

Questions Presented

1. Whether Bowling's post-judgment motion for leave to amend should be treated as a Rule 59(e) motion to alter or amend the judgment.
2. Whether the Rule 59(e) requirements for reopening the dismissed action were satisfied.
3. Whether Bowling was entitled to a hearing on his motion for leave to amend.

Disposition

other