Moncrief v. City of Montgomery (CONSENT)

CourtDistrict Court, M.D. Alabama
DecidedJuly 25, 2025
Docket2:23-cv-00331
StatusUnknown

This text of Moncrief v. City of Montgomery (CONSENT) (Moncrief v. City of Montgomery (CONSENT)) is published on Counsel Stack Legal Research, covering District Court, M.D. Alabama primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Moncrief v. City of Montgomery (CONSENT), (M.D. Ala. 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE MIDDLE DISTRICT OF ALABAMA NORTHERN DIVISION

JANICE MONCRIEF, individually, and ) as Administratrix of the Estate of Gary ) Moncrief, deceased, et al., ) ) Plaintiffs, ) ) v. ) CASE NO. 2:23-cv-331-JTA ) (WO) CITY OF MONTGOMERY, a municipal ) corporation of the State of Alabama, et al., ) ) Defendants. )

MEMORANDUM OPINION Before the Court1 is the motion to set aside entry of default filed by Defendants City of Montgomery, James Albrecht, and Christopher Brown. (Doc. No. 117.) For the reasons stated below, the motion is due to be granted. I. JURISDICTION This Court has subject matter jurisdiction over Plaintiffs’ federal claims pursuant to 28 U.S.C. §§ 1331 and 1343, and supplemental jurisdiction over their state law claims pursuant to 28 U.S.C. § 1367. The parties do not contest personal jurisdiction or venue, and there are adequate allegations to support both. See 28 U.S.C. § 1391.

1 The parties have consented to the exercise of dispositive jurisdiction by a magistrate judge pursuant to 28 U.S.C. § 636(c). II. FACTS AND PROCEDURAL HISTORY2 This case arises out of an incident on May 18, 2021. On that date, Defendants James

Albrecht and Christopher Brown, police officers for the City of Montgomery, used deadly force by firing into a vehicle that was occupied by four people. One of the occupants, Gary Moncrief, died due to a gunshot wound. Over two years ago, on May 17, 2023, Plaintiffs Janice Moncrief, Gary Moncrief’s mother and next of kin who sues in both her representative and individual capacities, along with Plaintiffs Benita Moncrief and Tamara Acree,3 filed this action against Defendants

City of Montgomery, Ernest N. Finley, Jr., James Albrecht, and Christopher Brown. (Doc. No. 1.) For purposes of this memorandum opinion, the Court will refer to Defendants City of Montgomery, James Albrecht, and Christopher Brown as the Original Defendants.4 After substantial litigation, including early discovery, resolution of a motion to dismiss, the filing of an amended complaint, and the filing of answers, on December 11,

2024, the Court entered a scheduling order that stated: “Motions to amend the pleadings and to add parties shall be filed by the parties on or before February 24, 2025.” (Docs. No.

2 Due to the voluminous record, this statement of procedural history contains only a summary of events relevant to the motions that were the subject of the hearing held on July 24, 2025. 3 Plaintiffs Janice Moncrief, Benita Moncrief, and Tamara Acree were among the occupants in the vehicle during the May 18, 2021 incident. 4 By Order entered September 10, 2024, the Court dismissed Plaintiffs’ claims against Defendant Finley. (Doc. No. 42.) 1–48; Doc. No. 49 at 2 ¶ 2.) Subsequently, the Court ordered the parties to mediate, which was unsuccessful.5 (Docs. No. 51–58.)

On February 21, 2025, Plaintiffs filed an unopposed motion to extend the deadline to amend the pleadings. (Doc. No. 59.) On February 24, 2025, Plaintiffs filed an unopposed amended motion to extend the deadline to amend the pleadings. (Doc. No. 60.) On February 24, 2025, the Court entered the following text order: For good cause, it is ORDERED that Plaintiffs’ [Doc. No. 59] Unopposed Motion to Extend Time to Amend the Pleadings and Amended Unopposed [Doc. No. 60] Motion to Extend Time to Amend the Pleadings are GRANTED. The December 11, 2024 [Doc. No. 49] Scheduling Order is AMENDED solely to the following extent: the deadline to file a motion to amend the pleadings is EXTENDED to and including March 10, 2025.

(Doc. No. 61.) On March 7, 2025, Plaintiffs filed another unopposed motion to extend the deadline to amend the pleadings. (Doc. No. 66.) On March 10, 2025, Plaintiffs filed an amended unopposed motion to extend time to amend the pleadings. (Doc. No. 69.) The Court granted the March 10, 2025 amended unopposed motion to extend the time to amend the pleadings,

5 Plaintiffs failed to timely file the document titled “Notice Concerning Mediation” as required by the Court’s December 11, 2024 order directing the parties to mediate. (See Doc. No. 51 at 2.) In response to a February 25, 2025 order to file the notice and show cause why they had not timely done so, Plaintiffs filed the notice and a separate document showing cause why they did not timely file the notice. (Docs. No. 62–64.) Notably, Plaintiffs apologized for the delay and stated they “did not intend to miss a deadline imposed in an order of this Honorable Court and ask[ed] that this Honorable Court not penalize the Plaintiffs for this unintentional oversight.” (Doc. No. 64 at 2 ¶ 5.) At no point in this litigation in response to Plaintiffs missing any deadline or failing to comply with the Federal Rules of Civil Procedure or court orders did the Original Defendants seek relief under Rule 41(b) or otherwise attempt to capitalize on the situation. See Fed. R. Civ. P. 41(b) (“If the plaintiff fails . . . to comply with these rules or a court order, a defendant may move to dismiss the action or any claim against it.”). extended the deadline to amend until March 17, 2025, and denied the March 7, 2025 motion to extend the time to amend the pleadings as moot. (Docs. No. 70, 71.)

On March 17, 2025, Plaintiffs again filed an unopposed motion for extension of time to amend the pleadings due to the logistical requirements of filing under seal some of the anticipated exhibits to the complaint. (Doc. No. 72.) On March 18, 2025, one day after the expiration of the then-existing deadline to amend, Plaintiffs filed a motion for leave to amend the complaint, which did not have attached to it a proposed amended complaint, as is required by the Court’s local rules. (Doc.

No. 73.) See M.D. Ala. LR 15.1. On the same date, Plaintiffs filed a second amended complaint without leave of court and a notice that exhibits to the second amended complaint were filed conventionally under seal. (Docs. No. 74–75.) The second amended complaint added new claims and named ten additional defendants (“the New Defendants”), eight of whom counsel for the Original Defendants also now represents. (Doc. No. 74.)

On March 25, 2025, the Court entered orders granting Plaintiffs’ March 18, 2025 motion for leave to amend the complaint, deeming the second amended complaint timely filed, and denying as moot Plaintiffs’ March 17, 2025 motion for an extension of time to amend the complaint. (Docs. No. 77, 78.) On May 7, 2025, because the Original Defendants had not answered the second

amended complaint, Plaintiffs filed an application for entry of default. (Doc. No. 94.) On May 20, 2025, the Clerk of Court entered default against the Original Defendants. (Doc. No. 108.) On May 21, 2025, all Defendants jointly filed an unopposed motion for an extension of time for the New Defendants to answer or otherwise respond to the second amended

complaint. (Doc. No. 113.) In the motion, they pointed out that uniform rather than staggered deadlines for the New Defendants to answer or otherwise respond to the second amended complaint would serve judicial efficiency and the ends of justice6 by allowing consolidated briefing.

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