Pruitt v. Lake

Opinion

IN THE UNITED STATES DISTRICT COURT EASTERN DISTRICT OF ARKANSAS NORTHERN DIVISION

CHARLES PRUITT, JR. PLAINTIFF ADC #091574

V. NO. 3:24-cv-186-DPM-ERE

SANDRA LAKE, et al. DEFENDANTS

ORDER

Pro se plaintiff Charles Pruitt, Jr. has moved to amend his complaint to add Wellpath Holdings, Inc., as a party Defendant. Doc. 35. Because Mr. Pruitt alleges no facts that would support a plausible claim against Wellpath, the motion is denied as futile. It is well settled that a corporation, such as Wellpath, cannot be held liable for the wrongful conduct of its employees in a § 1983 action. Burke v. North Dakota Dept. of Corrs. & Rehab., 294 F.3d 1043, 1044 (8th Cir. 2002). A corporation can only be held liable if it had unconstitutional policies or practices that caused Mr. Pruitt’s injuries. Id.; Johnson v. Hamilton, 452 F.3d 967, 973 (8th Cir. 2006); Sanders v. Sears Roebuck & Co., 984 F.2d 972, 975-976 (8th Cir. 1993). In his motion, Mr. Pruitt fails to allege that a Wellpath policy, custom, or practice violated his constitutional rights. Pursuant to Rule 15 of the Federal Rules of Civil Procedure, a court should “freely give leave [to amend] when justice so requires.” FED. R. CIV. P. 15(a)(3). However, the Court may appropriately deny amendment of a pleading for various

reasons, including futility of the proposed amendment. Sherman v. Winco Fireworks, Inc., 532 F.3d 709, 715 (8th Cir. 2008). Here, based on the lack of factual allegations in Mr. Pruitt’s motion, allowing him to amend his complaint would be futile. Reuter

v. Jax Ltd., Inc., 711 F.3d 918, 922 (8th Cir. 2013) (citations omitted) (“Duplicative and frivolous claims are futile.”). IT IS THEREFORE ORDERED THAT Mr. Pruitt’s motion to amend his complaint (Doc. 35) is DENIED! Dated 8 August 2025.

ZYV_. LMU

| Motions to amend are nondispositive pretrial motions, appropriately decided by a United States Magistrate Judge pursuant to 28 U.S.C. § 636(b)(1)(A). See Daley v. Marriott Int’l, Inc., 415 F.3d 889, 893 n.9 (8th Cir. 2005) (designating magistrate judge’s denial of motion to amend as an “order denying [a] nondispositive pretrial motion”).