UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA
MARTIN HUGHES,
Plaintiff, Civil Action No. 25 - 2270 (SLS) v. Judge Sparkle L. Sooknanan
THE DISTRICT OF COLUMBIA,
Defendant.
MEMORANDUM OPINION
Martin Hughes filed this lawsuit against the District of Columbia challenging the conduct
of District police officers during three incidents in 2018, 2021, and 2022. On February 9, 2026,
the Court dismissed Mr. Hughes’ Amended Complaint. Mem. Op., ECF No. 22. In short, the Court
found that Mr. Hughes’ allegations were too conclusory to state a plausible claim for relief. Id.
7–9. Mr. Hughes now moves to alter or amend the Court’s judgment under Federal Rule of Civil
Procedure 59(e) or, in the alternative, for leave to file a second amended complaint under Federal
Rule of Civil Procedure 15(a)(2). Mot., ECF No. 24. The District opposes. Opp., ECF No. 25. The
Court once again recognizes that Mr. Hughes has experienced significant harms because of his
various interactions with law enforcement. But because it may not grant him the relief he seeks
based on the record before it, the Court denies his motion.
DISCUSSION
A. Motion to Alter or Amend
Motions under Rule 59(e) are “discretionary” and “need not be granted unless the district
court finds that there is an ‘intervening change of controlling law, the availability of new evidence,
or the need to correct a clear error or prevent manifest injustice.’” Firestone v. Firestone, 76 F.3d 1205, 1208 (D.C. Cir. 1996) (citation omitted). Generally, such motions are “disfavored” and
should be “granted only when the moving party establishes extraordinary circumstances.”
Niedermeier v. Off. of Baucus, 153 F. Supp. 2d 23, 28 (D.D.C. 2001) (citing Anyanwutaku v.
Moore, 151 F.3d 1053, 1057–58 (D.C. Cir. 1998)). A motion that “repeats unsuccessful arguments,
or is made based on mere disagreement with the court’s judgment, will not survive scrutiny.” Greer
v. Bd. of Trs. of Univ. of D.C., No. 24-cv-710, 2025 WL 1186260, at *1 (D.D.C. Apr. 4, 2025)
(cleaned up). Because Mr. Hughes is proceeding pro se, the Court “liberally construe[s]” his
motion. Adams v. CIA, No. 20-cv-377, 2023 WL 4350083, at *1 (D.D.C. May 5, 2023) (quoting
Erickson v. Pardus, 551 U.S. 89, 94 (2007)).
Mr. Hughes’ motion does not establish that there has been an “intervening change of
controlling law” or the “availability of new evidence,” 1 so the only question is whether Mr. Hughes
demonstrates a “need to correct a clear error or prevent manifest injustice.” Firestone, 76 F.3d at
1208 (citation omitted). “Rule 59(e) sets a high bar for a finding of clear error, which is met when
the final judgment entered is ‘dead wrong[.]’” Ecological Rts. Found. v. U.S. Env’t Prot. Agency,
541 F. Supp. 3d 34, 57 (D.D.C. 2021) (quoting CNN, Inc. v. FBI, 401 F. Supp. 3d 187, 193 (D.D.C.
2019)). Clear error can occur “because of ‘errors of fact appearing on the face of the record, or
errors of law.’” Id. (quoting Jud. Watch, Inc. v. U.S. Dep’t of State, 282 F. Supp. 3d 338, 341
(D.D.C. 2017)). The District argues that no such error occurred here. The Court agrees.
1 Mr. Hughes alerts the Court that the D.C. Superior Court recently granted motions to seal records related to his 2018 and 2021 arrests. See Reply 1–2, ECF No. 26; see also Orders to Seal, ECF No. 26-1. He relies on these sealing orders to argue that “dismissal of his claims . . . would result in manifest injustice.” Reply 2. He does not argue that the records constitute “new evidence,” which is not surprising given that they do not identify any new evidence relevant to the instant claims. See Orders to Seal.
2 The Court’s Opinion was based on a careful review of Mr. Hughes’ Amended Complaint
and his other filings in opposition to the District’s Motion to Dismiss. See Mem. Op. 2 (noting that
because Mr. Hughes is pro se, the Court considered his complaint “in light of all filings, including
filings responsive to the motion to dismiss” (quoting Brown v. Whole Foods Mkt. Grp. Inc., 789
F.3d 146, 152 (D.C. Cir. 2015)). Based on its review of those filings and of the relevant case law,
the Court found that Mr. Hughes’ allegations were too conclusory to state plausible claims for
relief. Id. 4. In his Rule 59(e) motion, Mr. Hughes does not advance any new legal arguments or
identify any relevant facts suggesting that a different conclusion was warranted, much less that the
Court’s conclusion was “dead wrong.” CNN, Inc., 401 F. Supp. 3d at 193 (cleaned up).
Mr. Hughes’ arguments regarding manifest injustice are similarly unavailing. “[M]anifest
injustice is an exceptionally narrow concept and arises from rulings that upset settled
expectations—expectations on which a party might reasonably place reliance.’” Greer, 2025 WL
1186260, at *2 (cleaned up). Mr. Hughes has not shown that failure to grant his motion will result
in manifest injustice. As the Court noted in its Opinion, it is sympathetic to the lasting impact that
Mr. Hughes’ interactions with law enforcement have had on his life. Mem. Op. 1. And it
recognizes the importance of Mr. Hughes successfully getting his arrest records from 2018 and
2021 sealed. See Orders to Seal, ECF No. 26-1. But the sealing of those records simply does not
alter the Court’s analysis. Indeed, as explained below, Mr. Hughes still has not stated a plausible
claim for relief. Thus, dismissal creates no manifest injustice.
B. Motion for Leave to Amend
Rule 15(a)(1) permits a party to “amend its pleading once as a matter of course
[within] . . . 21 days after service of a motion under Rule 12(b).” Fed. R. Civ. P. 15(a)(1). Outside
of that time, Rule 15(a)(2) allows a party to amend its pleading “only with the opposing party’s
3 written consent or the court’s leave.” Fed. R. Civ. P. 15(a)(2). While leave to amend should
generally be “freely given,” see Foman v. Davis, 371 U.S. 178, 182 (1962), it may be denied if the
amendment would be futile—i.e., the proposed amended complaint “would not survive a motion
to dismiss,” Hettinga v. United States, 677 F.3d 471, 480 (D.C. Cir. 2012).
Here, the District urges the Court to deny Mr. Hughes’ motion because the proposed
amendment would be futile. Having reviewed the proposed amendment, the Court agrees. Again,
Mr. Hughes’ claims arise from three incidents that occurred in 2018, 2021, and 2022. His proposed
Second Amended Complaint makes clear that any claims predicated on the 2018 and 2021
incidents are time-barred. Proposed Second Am. Compl. (SAC), ECF No. 24-1. And the
allegations regarding the final incident in 2022 are still too conclusory to state a plausible claim.
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UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA
MARTIN HUGHES,
Plaintiff, Civil Action No. 25 - 2270 (SLS) v. Judge Sparkle L. Sooknanan
THE DISTRICT OF COLUMBIA,
Defendant.
MEMORANDUM OPINION
Martin Hughes filed this lawsuit against the District of Columbia challenging the conduct
of District police officers during three incidents in 2018, 2021, and 2022. On February 9, 2026,
the Court dismissed Mr. Hughes’ Amended Complaint. Mem. Op., ECF No. 22. In short, the Court
found that Mr. Hughes’ allegations were too conclusory to state a plausible claim for relief. Id.
7–9. Mr. Hughes now moves to alter or amend the Court’s judgment under Federal Rule of Civil
Procedure 59(e) or, in the alternative, for leave to file a second amended complaint under Federal
Rule of Civil Procedure 15(a)(2). Mot., ECF No. 24. The District opposes. Opp., ECF No. 25. The
Court once again recognizes that Mr. Hughes has experienced significant harms because of his
various interactions with law enforcement. But because it may not grant him the relief he seeks
based on the record before it, the Court denies his motion.
DISCUSSION
A. Motion to Alter or Amend
Motions under Rule 59(e) are “discretionary” and “need not be granted unless the district
court finds that there is an ‘intervening change of controlling law, the availability of new evidence,
or the need to correct a clear error or prevent manifest injustice.’” Firestone v. Firestone, 76 F.3d 1205, 1208 (D.C. Cir. 1996) (citation omitted). Generally, such motions are “disfavored” and
should be “granted only when the moving party establishes extraordinary circumstances.”
Niedermeier v. Off. of Baucus, 153 F. Supp. 2d 23, 28 (D.D.C. 2001) (citing Anyanwutaku v.
Moore, 151 F.3d 1053, 1057–58 (D.C. Cir. 1998)). A motion that “repeats unsuccessful arguments,
or is made based on mere disagreement with the court’s judgment, will not survive scrutiny.” Greer
v. Bd. of Trs. of Univ. of D.C., No. 24-cv-710, 2025 WL 1186260, at *1 (D.D.C. Apr. 4, 2025)
(cleaned up). Because Mr. Hughes is proceeding pro se, the Court “liberally construe[s]” his
motion. Adams v. CIA, No. 20-cv-377, 2023 WL 4350083, at *1 (D.D.C. May 5, 2023) (quoting
Erickson v. Pardus, 551 U.S. 89, 94 (2007)).
Mr. Hughes’ motion does not establish that there has been an “intervening change of
controlling law” or the “availability of new evidence,” 1 so the only question is whether Mr. Hughes
demonstrates a “need to correct a clear error or prevent manifest injustice.” Firestone, 76 F.3d at
1208 (citation omitted). “Rule 59(e) sets a high bar for a finding of clear error, which is met when
the final judgment entered is ‘dead wrong[.]’” Ecological Rts. Found. v. U.S. Env’t Prot. Agency,
541 F. Supp. 3d 34, 57 (D.D.C. 2021) (quoting CNN, Inc. v. FBI, 401 F. Supp. 3d 187, 193 (D.D.C.
2019)). Clear error can occur “because of ‘errors of fact appearing on the face of the record, or
errors of law.’” Id. (quoting Jud. Watch, Inc. v. U.S. Dep’t of State, 282 F. Supp. 3d 338, 341
(D.D.C. 2017)). The District argues that no such error occurred here. The Court agrees.
1 Mr. Hughes alerts the Court that the D.C. Superior Court recently granted motions to seal records related to his 2018 and 2021 arrests. See Reply 1–2, ECF No. 26; see also Orders to Seal, ECF No. 26-1. He relies on these sealing orders to argue that “dismissal of his claims . . . would result in manifest injustice.” Reply 2. He does not argue that the records constitute “new evidence,” which is not surprising given that they do not identify any new evidence relevant to the instant claims. See Orders to Seal.
2 The Court’s Opinion was based on a careful review of Mr. Hughes’ Amended Complaint
and his other filings in opposition to the District’s Motion to Dismiss. See Mem. Op. 2 (noting that
because Mr. Hughes is pro se, the Court considered his complaint “in light of all filings, including
filings responsive to the motion to dismiss” (quoting Brown v. Whole Foods Mkt. Grp. Inc., 789
F.3d 146, 152 (D.C. Cir. 2015)). Based on its review of those filings and of the relevant case law,
the Court found that Mr. Hughes’ allegations were too conclusory to state plausible claims for
relief. Id. 4. In his Rule 59(e) motion, Mr. Hughes does not advance any new legal arguments or
identify any relevant facts suggesting that a different conclusion was warranted, much less that the
Court’s conclusion was “dead wrong.” CNN, Inc., 401 F. Supp. 3d at 193 (cleaned up).
Mr. Hughes’ arguments regarding manifest injustice are similarly unavailing. “[M]anifest
injustice is an exceptionally narrow concept and arises from rulings that upset settled
expectations—expectations on which a party might reasonably place reliance.’” Greer, 2025 WL
1186260, at *2 (cleaned up). Mr. Hughes has not shown that failure to grant his motion will result
in manifest injustice. As the Court noted in its Opinion, it is sympathetic to the lasting impact that
Mr. Hughes’ interactions with law enforcement have had on his life. Mem. Op. 1. And it
recognizes the importance of Mr. Hughes successfully getting his arrest records from 2018 and
2021 sealed. See Orders to Seal, ECF No. 26-1. But the sealing of those records simply does not
alter the Court’s analysis. Indeed, as explained below, Mr. Hughes still has not stated a plausible
claim for relief. Thus, dismissal creates no manifest injustice.
B. Motion for Leave to Amend
Rule 15(a)(1) permits a party to “amend its pleading once as a matter of course
[within] . . . 21 days after service of a motion under Rule 12(b).” Fed. R. Civ. P. 15(a)(1). Outside
of that time, Rule 15(a)(2) allows a party to amend its pleading “only with the opposing party’s
3 written consent or the court’s leave.” Fed. R. Civ. P. 15(a)(2). While leave to amend should
generally be “freely given,” see Foman v. Davis, 371 U.S. 178, 182 (1962), it may be denied if the
amendment would be futile—i.e., the proposed amended complaint “would not survive a motion
to dismiss,” Hettinga v. United States, 677 F.3d 471, 480 (D.C. Cir. 2012).
Here, the District urges the Court to deny Mr. Hughes’ motion because the proposed
amendment would be futile. Having reviewed the proposed amendment, the Court agrees. Again,
Mr. Hughes’ claims arise from three incidents that occurred in 2018, 2021, and 2022. His proposed
Second Amended Complaint makes clear that any claims predicated on the 2018 and 2021
incidents are time-barred. Proposed Second Am. Compl. (SAC), ECF No. 24-1. And the
allegations regarding the final incident in 2022 are still too conclusory to state a plausible claim.
First, the claims challenging the 2018 and 2021 incidents are time-barred. Mr. Hughes’
claims under 42 U.S.C. § 1983 are subject to a three-year statute of limitations. Earle v. Dist. of
Columbia, 707 F.3d 299, 305 (D.C. Cir. 2012). Mr. Hughes filed this lawsuit on October 22, 2024.
ECF No. 1-2. He is thus barred from asserting claims that accrued more than three years before
that date—i.e., before October 22, 2021. “As a general rule, a claim normally accrues when the
factual and legal prerequisites for filing suit are in place.” Id. at 306 (cleaned up). Here, the factual
and legal prerequisites for Mr. Hughes to challenge the 2018 and 2021 incidents appear to have
been present when those incidents occurred. The 2018 incident is thus clearly outside the three-
year window that preceded this suit. And while it was not clear from Mr. Hughes’ Amended
Complaint that the 2021 incident was time-barred, see Am. Compl., ECF No. 14 (identifying the
incident only by year and not month or day), his proposed Second Amended Complaint dispels
any uncertainty. It clearly places that incident on February 28, 2021, SAC 1, well outside the three-
year window.
4 Mr. Hughes’ argument that the Court should apply the “relation back” doctrine under
Rule 15(c) does not alter this conclusion. See Reply 2–3, ECF No. 26. The problem is not that
Mr. Hughes failed to sue the correct officers within the three-year window. The problem is that he
did not sue anyone (the District or any officers, named or unnamed) within three years of the 2018
and 2021 incidents. There is thus no timely filed lawsuit regarding those incidents to which his
proposed Second Amended Complaint can relate back.
Second, even if Mr. Hughes has a timely claim related to the 2022 incident, it has not been
plausibly alleged. The Court previously dismissed Mr. Hughes’ alleged constitutional violations
because they were “‘legal conclusions’ that [we]re not supported by ‘the facts set out in the
complaint’ or by inferences that [could] reasonably be drawn from those facts.” Mem. Op. 7
(quoting Trudeau v. FTC, 456 F.3d 178, 193 (D.C. Cir. 2006)). Had Mr. Hughes sought
amendment with concrete factual allegations to support his claims, the Court would have granted
him an opportunity to amend. But Mr. Hughes’ proposed Second Amended Complaint says even
less about the 2022 incident than the operative Amended Complaint. Compare Am. Compl. with
SAC. Indeed, the only thing that it says about the 2022 incident is that it and the 2018 incident
were “similar encounters” to the incident that Mr. Hughes experienced in 2021 and “result[ed] in
arrests without conviction and continued retention of property.” SAC 2. This single allegation is
simply not enough to state a plausible claim that the District or any of its officers violated
Mr. Hughes’ constitutional rights during the 2022 incident. Accordingly, permitting Mr. Hughes
to amend to advance this claim would be futile. Hettinga, 677 F.3d at 480.
5 CONCLUSION
For all these reasons, the Court denies Mr. Hughes’ Motion to Alter or Amend the Court’s
prior judgment or, in the alternative, for Leave to Amend his Complaint. ECF No. 24.
A separate order will issue.
SPARKLE L. SOOKNANAN United States District Judge Date: March 31, 2026