Mamadou L. Bah v. Royal Air Maroc

Summary

The United States District Court for the Southern District of New York grants pro se plaintiff Mamadou L. Bah leave to amend his complaint against Royal Air Maroc. The court finds no undue delay, bad faith, prejudice, or futility sufficient to deny amendment, and directs Bah to file an amended complaint by December 31, 2025. The order also sets a schedule for Defendant's response and subsequent motion practice.

Holdings

1. A pro se plaintiff should generally be afforded at least one opportunity to amend a complaint unless amendment would be futile or there is undue delay, bad faith, or prejudice.
2. The proposed amendment was not shown to be futile because Bah might be able to allege additional facts, including physical injury, that could state a valid claim depending on whether the Montreal Convention governs the action.
3. The record did not establish undue delay, bad faith, or prejudice sufficient to deny leave to amend.

Questions Presented

1. Whether Bah should be granted leave to amend his complaint under Federal Rule of Civil Procedure 15(a)(2).
2. Whether the proposed amendment would be futile because the Montreal Convention might govern and preclude Bah's asserted claims.
3. Whether undue delay, bad faith, or prejudice warranted denying leave to amend.

Disposition

other