Lang v. District of Columbia

District Court, District of Columbia·Decided July 6, 2026·No. Civil Action No. 2020-1199·Published

Opinion

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA

SHEILA LANG, Plaintiff,

v. No. 20-cv-1199 (TSC)

DISTRICT OF COLUMBIA, et al., Defendants.

OPINION & ORDER

Plaintiff Sheila Lang, a former teacher at the District of Columbia Public Schools (“DCPS”), filed this lawsuit against the District of Columbia and former DCPS Principal Anna Krughoff, alleging employment discrimination and First Amendment violations. In March 2023, the court granted in part and denied in part Defendant’s motion to dismiss the Third Amended Complaint, allowing Plaintiff to proceed with her First Amendment claim against Krughoff and her hostile work environment claims against the District. See Mem. Op. at 28, ECF No. 25.1 As the case proceeded to discovery, the court set a June 2023 deadline for amended pleadings. See Scheduling Order, ECF No. 29.

Approximately two-and-a-half years after that deadline, in January 2026, Plaintiff moved for leave to file a Fourth Amended Complaint. See Pl.’s Mot., ECF No. 60; see also Proposed Fourth Am. Compl., ECF No. 60-1 (“FAC”). She seeks to revive her dismissed First Amendment municipal liability and retaliation claims and add allegations to buttress her non- dismissed claims. See Pl.’s Mot. at 3–4. Defendants oppose further amendment. See Defs.’

1 For a more detailed overview of this case’s background and procedural history, see Memorandum Opinion, ECF No. 25.

Opp’n, ECF No. 68. Despite receiving two extensions to reply to Defendants’ Opposition, see Min. Order (Apr. 15, 2026), Min. Order (Apr. 16, 2026), Plaintiff’s counsel was late to file a Reply, see Pl.’s Reply, ECF No. 73. Although the court will GRANT Plaintiff’s motion to accept the late filed and overlength Reply, ECF No. 74, the court will DENY Plaintiff’s motion for leave to file a Fourth Amended Complaint, ECF No. 60.

I. LEGAL STANDARDS

Federal Rule of Civil Procedure 15(a) ordinarily governs a motion for leave to amend a complaint. Under Rule 15(a)’s “liberal standard for granting leave,” Firestone v. Firestone, 76 F.3d 1205, 1208 (D.C. Cir. 1996), “leave to amend should be freely given unless there is a good reason, such as futility, to the contrary.” Willoughby v. Potomac Elec. Power Co., 100 F.3d 999, 1003 (D.C. Cir. 1996). But when a plaintiff seeks to amend after the scheduling order deadline for amendment has passed, “the more stringent good cause standard imposed by” Rule “16(b) applies.” In re Papst Licensing GmbH & Co. KG Litig., 762 F. Supp. 2d 56, 59 (D.D.C. 2011); see also Sacerdote v. NYU, 9 F.4th 95, 115 (2d Cir. 2021) (“The period of ‘liberal’ amendment ends if the district court issues a scheduling order setting a date after which no amendment will be permitted.”); Cheeks v. Belmar, 162 F.4th 899, 907 (8th Cir. 2025) (“Rule 16(b)—rather than Rule 15(a)—governs the amendment of pleadings after the [scheduling order] deadline expires.”).

“To show good cause under” that “more stringent” standard, “the moving party must show both diligence and a lack of prejudice to the opposing parties.” In re Papst, 762 F. Supp. 2d at 59 (emphasis added). The primary consideration is diligence; “if the party was not diligent, the inquiry should end.” United States v. Kellogg Brown & Root Servs., 285 F.R.D. 133, 136 (D.D.C. 2012) (quoting Johnson v. Mammoth Recreations, Inc., 975 F.2d 604, 609 (9th Cir.

1992)). “Only after the movant shows good cause may the court consider whether amendment is [also] proper under Rule 15(a).” Cheeks, 162 F.4th at 907; see also 6A Charles Alan Wright & Arthur R. Miller, Fed. Prac. & Proc. Civ. § 1522.2 (3d ed. 2026) (“[T]he Rule 16(b) standard controls any decisions to alter a scheduling order for purposes of making pleading amendments and it must be satisfied before determining whether an amendment should be permitted under Rule 15.”).

II. ANALYSIS

Plaintiff’s counsel contends that during discovery he learned of evidence to support ten sets of new allegations. See Pl.’s Mot. at 2–3. Defendants argue that Plaintiff’s counsel had most of this evidence by early April 2024, and that his one-year-and-nine-month delay in moving to amend—approximately two-and-a-half years after the amended pleadings deadline—reflects a lack of diligence. See Defs.’ Opp’n at 10. The court agrees with Defendants.

a. Family Issues and Workload As an initial matter, Plaintiff’s counsel attributes roughly six months of delay to his obligations as his father’s “primary caregiver” and his father’s death. Pl.’s Reply at 7, ECF No. 73. Specifically, counsel’s father became “terribly ill” around late April 2024 and passed away on September 2, 2024. Id. According to Plaintiff’s counsel, that means any delay until mid- October 2024—“or about one month after [his] father’s funeral”—is categorically justified. Id. Plaintiff’s counsel also justifies this and other delays by pointing to his responsibilities “working for other clients.” Id. at 8. But although counsel “regrettably suffered through a period of personal hardship” and had competing work demands, “‘a lawyer’s duty of diligence transcends both upheaval at work and personal tragedy.’” Strong-Fischer v. Peters, 554 F. Supp. 2d 19, 25 (D.D.C. 2008) (quoting Davila-Alvarez v. Escuela de Medicina Universidad Cent. del Caribe, 257 F.3d 58, 65 (1st Cir. 2001)). Even if personal tragedy excuses some delay, it cannot justify six months’ worth. Cf. Davila-Alvarez, 257 F.3d at 65 (reasoning that counsel “was not relieved” of his “ongoing responsibility to inquire into the status of a case” by “his brother’s untimely death”); Harrington v. City of Chicago, 433 F.3d 542, 548 (7th Cir. 2006) (holding that counsel’s “abandonment of the case during discovery . . . cannot be excused by the deaths in his family”). Nor does counsel’s status as “a busy sole-practitioner . . . relieve [him] of [his] duty to diligently pursue discovery.” Gaines v. United States, 54 F. App’x 797 (5th Cir. 2002). “That an attorney has other matters in his office which require his attention does not constitute excuse for neglect of attention to any one matter.” Citizens’ Protective League v. Clark, 178 F.2d 703, 704 (D.C. Cir. 1949); see also Stonkus v. City of Brockton Sch. Dep’t, 322 F.3d 97, 101 (1st Cir. 2003) (“Most attorneys are busy most of the time and they must organize their work so as to be able to meet the requirements of the matters they are handling or suffer the consequences.” (cleaned up)).

b. New Allegations As for the ten sets of new allegations, Plaintiff’s counsel largely does not dispute that the evidence underlying most of them was turned over in April 2024 or otherwise already available to him.2 Beginning with the first two sets of new allegations, Plaintiff’s counsel states that

2 The ten sets of new allegations are: “(1) the identity of the defendants’ major coconspirators;

(2) relevant emails to and from those coconspirators; (3) the District’s illegal, secret investigations of Lang wherein the District violated the law by never affording Lang with notice of those investigations and by never granting Lang’s right to defend against those investigations; (4) the adverse actions imposed against Lang during those illegal investigations;

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