Hill v. AutoZone Stores LLC

District Court, N.D. Indiana·Decided May 22, 2025·No. 1:24-cv-00012·Unknown

Opinion

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF INDIANA FORT WAYNE DIVISION

MICHAEL D HILL,

Plaintiff,

v. Case No. 1:24-CV-12-CCB-SLC

AUTOZONE STORES LLC, et al.,

Defendants.

OPINION AND ORDER Before the Court is Plaintiff Michael D. Hill’s (“Hill”) Motion to Reconsider (ECF 49) this Court’s Opinion and Order dated February 6, 2025 (ECF 37) denying his motion for leave to amend his complaint to include a claim for intentional infliction of emotional distress against Defendants AutoZone Stores, LLC (“AutoZone”) and Natasha Lefevra (“Lefevra”). Based on the applicable law, facts, and arguments, Plaintiff’s motion to reconsider will be DENIED. I. RELEVANT BACKGROUND Hill alleges that in June 2023, he went to AutoZone to return a defective auto part. (ECF 5 at 1). Hill allegedly explained to Lefevra, AutoZone’s store manager, that he purchased the part from another AutoZone location, but that Lefevra disputed Hill’s entitlement to a refund. (Id. at 1, 2). Lefevra allegedly refused to check whether Hill could be refunded even when Hill allegedly had receipts, and accused Hill of trying to “scam her” and “get free money.” (Id. at 2). Hill then alleges he cursed at Lefevra, and Lefevra responded by calling him a racial slur. (Id.). As Hill was walking away, Lefevra allegedly approached Hill, attempted to provoke Hill into hitting her, and chest bumped Hill. (Id.).

On December 5, 2023, Hill commenced a lawsuit in Indiana state court against Defendants AutoZone and Lefevra. (ECF 5). AutoZone removed the case to this Court on January 10, 2024. (ECF 1). On March 13, 2024, Lefevra moved to dismiss under Fed. R. Civ. P. 12(b), and AutoZone moved to join Lefevra’s motion. (ECF 21, 23). Under Fed. R. Civ. P. 15(a)(1), the last day for Hill to amend his pleadings without leave of Court was April 3, 2024. On April 18, 2024, Hill filed a motion for leave

to amend his complaint in lieu of a response to Defendants’ motion to dismiss. (ECF 32). Hill sought to amend his complaint to assert claims against both AutoZone and Lefevra for violating his rights under 42 U.S.C. § 1981 (Count I), assault and battery (Count II) and intentional infliction of emotional distress (“IIED”) (Count III). On February 6, 2025, the Court denied Hill’s motion for leave to amend his complaint to include Count III

against Defendants AutoZone and Lefevra for intentional infliction of emotional distress but granted Hill's motion for leave to amend his complaint as to Count I and Count II in the proposed amended complaint. (ECF 37). The Court ordered Hill to file his proposed amended complaint containing the remaining allegations and claims by February 13, 2025. (Id.).

Hill did not file his proposed amended complaint. Instead, on March 6, 2025, Hill filed a motion for an extension of time to file a motion to reconsider (ECF 47), which was granted by Magistrate Judge Collins on March 21, 2025 (ECF 48). On March 21, 2025, Hill filed a motion for reconsideration under Fed. Civ. P. R. 59(e). (ECF 49). Two weeks later, Hill filed a memorandum in support of his motion for reconsideration. (ECF 50). Both AutoZone and Lefevra have filed responses in opposition to Hill’s

motion to reconsider. (ECF 52, 54). II. STANDARD Hill invokes Fed. R. Civ. P. 59 in seeking reconsideration of the Court’s February 2025 Opinion and Order denying his motion for leave to amend his complaint to include a claim for intentional infliction of emotional distress. Rule 59 governs motions for new trials and motions to alter or amend a judgment. No trial has been held. No judgment has been entered either.

Therefore, Hill’s motion for reconsideration falls outside the scope of Rule 59. Hill’s motion more properly falls within the scope of Fed. R. Civ. P. 54(b), which embodies the inherent power of courts to revise non-final orders as justice requires before entry of final judgment. Cf. e.g., Shure, Inc. v. ClearOne, Inc., No. 17 C 3078, 2019 WL 4014230, at *2 (N.D. Ill. Aug. 25, 2019); First Specialty Ins. v. Supreme Corp., No. 3:12-CV-186 JD, 2018 WL 4680015, at *1 (N.D. Ind. Sept.

28, 2018). However, even if Rule 59(e) did apply here, Hill’s argument still fails. Motions for reconsideration are disfavored but can serve limited valuable functions to correct manifest errors of law or fact; consider newly discovered evidence; or address errors of apprehension. Bank of Waunakee v. Rochester Cheese Sales, Inc., 906 F.2d 1185, 1191 (7th Cir. 1990); see also Publishers Res., Inc. v. Walker-Davis Publ’ns, Inc. 762 F.2d 557, 561 (7th Cir. 1985)

(quotation omitted). “A manifest error is not demonstrated by the disappointment of the losing party.” Oto v. Metro. Life Ins., 224 F.3d 601, 606 (7th Cir. 2000) (internal quotation omitted). “It is the wholesale disregard, misapplication, or failure to recognize controlling precedent.” Id. (internal quotation omitted). As such, motions for reconsideration are not to be used to advance arguments that the Court has addressed and decided. See Caisse Nationale de Credit Agricole v. CBI Indus., Inc., 90 F.3d 1264, 1270 (7th Cir. 1996). “Indeed, the court’s orders

are not mere first drafts, subject to revision and reconsideration at a litigant’s pleasure.” Lock Realty Corp. IX v. U.S. Health, LP, No. 3:06-CV-487RM, 2010 WL 148296, at *1 (N.D. Ind. Jan. 13, 2010). “The opportunity to present a motion to reconsider should not be viewed as a second opportunity for the losing party to make its strongest case or to dress up arguments that previously failed.” Indiana v. Helman, No. 1:08CR48-TS, 2008 WL 2557246, at *1 (N.D. Ind. June 23, 2008) (internal quotation omitted).

III. ANALYSIS Both AutoZone and Lefevra argue that Hill’s memorandum of law in support of his motion to reconsider is untimely. (ECF 52 at 3) (ECF 54 at 1). The Court agrees. The Court granted Hill’s motion for an extension of time to file a motion to reconsider and set a deadline of March 21, 2025, to file the motion to reconsider. (ECF 48). Hill filed the

motion to reconsider on the deadline and did not file the memorandum in support of the motion to reconsider until two weeks later, on April 3, 2025. (ECF 50). The Seventh Circuit has rejected efforts to get around Rule 59(e) deadlines by filing placeholder motions and then filing a memorandum of law with argument later. The court in Lac du Flambeau stated that “[a]n empty motion cannot reserve time to file an explanation after

the ten days allowed by Rule 59.” Lac Du Flambeau Band of Lake Superior Chippewa Indians v. Wis., 957 F.2d 515, 516–17 (7th Cir. 1992); see also Hope v. United States, 43 F.3d 1140, 1143 (7th Cir. 1994).

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