Webb v. Detroit, City of

CourtDistrict Court, E.D. Michigan
DecidedJune 9, 2025
Docket4:24-cv-12895
StatusUnknown

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

Bluebook
Webb v. Detroit, City of, (E.D. Mich. 2025).

Opinion

UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF MICHIGAN SOUTHERN DIVISION

DEREK DENNIS WEBB, Case No. 24-12895 Plaintiff, v. F. Kay Behm United States District Judge CITY OF DETROIT, et al., Defendants. Curtis Ivy, Jr. ____________________________/ United States Magistrate Judge

ORDER ON MOTIONS AT ECF Nos. 19, 30, 31, 39, 42, 43

Plaintiff, who is proceeding without counsel, filed this civil rights lawsuit on November 1, 2024. He sues the City of Detroit, the Detroit Police Department, four police officers, and unknown John Doe officers concerning his arrest and detention during October 2022. (ECF No. 1). Before the Court are several motions Plaintiff filed (ECF Nos. 30, 31, 39, 42, 43) and the City of Detroit’s motion to dismiss (ECF No. 19). A. Motion to Dismiss and Plaintiff’s Motion to Amend Defendant City of Detroit moved to dismiss the complaint on January 21, 2025, for failure to state any allegations against it. (ECF No. 19). Plaintiff timely responded to the motion on February 3, 2025. (ECF No. 24). Then, on March 3, 2025, Plaintiff moved to amend his complaint. (ECF No. 30, 32). About two weeks later, Defendants other than the City of Detroit and the police department (which has not appeared) answered the original complaint. (ECF No. 35). Given the timing of Plaintiff’s motion to amend and Defendants’ answer that followed it, the Court ordered the Defendants to respond to the motion to amend to

address whether Plaintiff could amend as of right. (ECF No. 36). The police officer defendants appear to concede that Plaintiff could amend as of right against them, but they object to Plaintiff filing the amended complaint because it does not

comply with the Federal Rules of Civil Procedure. The City of Detroit did not substantively participate in the response. (ECF No. 37). Plaintiff could not amend as of right, so his moving to amend was appropriate. Parties can amend their pleadings once as a matter of right “no later

than . . . 21 days after serving it,” or 21 days after service of a responsive pleading (an answer) or 21 days after service of a motion to dismiss, whichever is earlier. Fed. R. Civ. P. 15(a)(1). “In cases with multiple defendants, ‘parties cannot add

together, or make ‘cumulative,’ twenty-one-day periods after opposing parties file separate responsive pleadings or motions to dismiss at different times.’” DPH Mech. Contractors, Inc. v. Berkley Se. Ins. Grp., 2025 WL 44148, at *1 (W.D. Tenn. Jan. 7, 2025) (quoting Evans v. City of Ann Arbor, 2021 WL 2949502, at *2

(E.D. Mich. July 14, 2021)); see also § 1481 Amendments as of Course—Actions By or Against More Than One Party, 6 Fed. Prac. & Proc. Civ. § 1481 (3d ed.) (“the sounder approach is to require a motion for leave to amend so that the court

may consider the possible effects of the proposed amendment on the other parties to the action.”). Thus, under Rule 15(a), Plaintiff had 21 days from the date of the earliest responsive document—the City of Detroit’s January 21, 2025 motion to

dismiss—to amend his complaint as of right. Because Plaintiff did not seek amendment until after that 21-day period, he needed to file a motion to amend, as he did.

The only opposition to Plaintiff’s motion to amend is that the proposed amended complaint does not have consecutively numbered paragraphs and that “[i]t is not clear from Plaintiff’s proposed amended complaint the factual or legal basis of his claim for relief, and his proposed amended complaint cannot be fairly

described as short or plain.” (ECF No. 37, PageID.341). Defendants said that if Plaintiff is permitted to amend his complaint, they will move for a more definite statement under Fed. R. Civ. P. 12(e).

Under Rule 15(a)(2), “[t]he court should freely give leave [to amend] when justice so requires.” That said, this does not suggest that all motions to amend are automatically granted. Courts consider several factors when assessing a motion to amend, namely “the delay in filing, the lack of notice to the opposing party, bad

faith by the moving party, repeated failure to cure deficiencies by previous amendments, undue prejudice to the opposing party, and futility of amendment.” Perkins v. Am. Elec. Power Fuel Supply, Inc., 246 F.3d 593, 605 (6th Cir. 2001).

Amendment of a complaint is futile when the proposed amendment would not permit the complaint to survive a motion to dismiss. Miller v. Calhoun Cnty., 408 F.3d 803, 817 (6th Cir. 2005) (citing Neighborhood Dev. Corp. v. Advisory

Council on Historic Pres., 632 F.2d 21, 23 (6th Cir. 1980)). Defendants do not argue against the timing or substance of the proposed amended complaint, but they contest the style of the proposed pleading. The Court

agrees that the way the proposed amended complaint is drafted could cause confusion as the litigation progresses. As Defendants note, Plaintiff did not consecutively number his paragraphs. Instead, the paragraphs begin at “1” in each new section. Rule 10(b) requires the complaint to be stated in numbered

paragraphs, and those paragraphs should be consecutive (beginning with 1 and continuing through until the end of the entire compliant). So Plaintiff’s motion to amend the complaint is GRANTED, but Plaintiff must file a new amended

complaint that is properly numbered. In doing so, he should take care to clearly state the factual allegations supporting his claims. This new amended complaint is due by June 25, 2025. If Plaintiff does not file the new amended complaint by this date, the Court and the parties will proceed with the proposed amended

complaint as the operative complaint. If after June 25, 2025, Plaintiff has not filed the new amended complaint, then Defendants must respond to the proposed amended complaint (ECF No. 32) within 21 days of June 25, 2025. An amended complaint supersedes the original complaint. Drake v. City of Detroit, 266 F. App’x 444, 448 (6th Cir. 2008). Now that Plaintiff has been given

leave to amend his complaint, the City of Detroit’s motion to dismiss the original complaint is DENIED WITHOUT PREJUDICE AS MOOT. See Nails v. RPI- Section 8 Hous., 2019 WL 1112381, at *4 (E.D. Mich. Mar. 11, 2019) (quoting

Heard v. Strange, 2018 WL 4189652, at *2 (E.D. Mich. June 21, 2018)) (collecting cases). The City did not argue that the amendment would be futile for the reasons stated in its motion to dismiss, and the Court is not in a position to assess the sufficiency of the pleadings on its own because Plaintiff is not

proceeding in forma pauperis. See 28 U.S.C. § 1915(e) (requiring the Court to dismiss the case brought by a plaintiff in forma pauperis at any time if the Court determines that the action is frivolous or fails to state a claim).

B. Plaintiff’s Other Motions On March 11, 2025, Plaintiff filed a motion that appears to request surveillance video from the date of his arrest. (ECF No. 31). Then, on May 13, 2025, Plaintiff moved for a 21-day extension of time for Defendants to produce the

surveillance video. (ECF No. 42). On May 16, 2025, he moved to have Defendants produce documents, including an incident or investigation report. (ECF No. 43). These motions are DENIED. Plaintiff is seeking discovery prematurely. In civil cases,

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