Webb v. Kentucky Justice and Public Safety Cabinet, Department of State Police

CourtDistrict Court, E.D. Kentucky
DecidedMarch 8, 2023
Docket3:22-cv-00011
StatusUnknown

This text of Webb v. Kentucky Justice and Public Safety Cabinet, Department of State Police (Webb v. Kentucky Justice and Public Safety Cabinet, Department of State Police) is published on Counsel Stack Legal Research, covering District Court, E.D. Kentucky primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Webb v. Kentucky Justice and Public Safety Cabinet, Department of State Police, (E.D. Ky. 2023).

Opinion

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF KENTUCKY CENTRAL DIVISION FRANKFORT

) MICHAEL B. WEBB, ) ) Plaintiff, ) Civil No. 3:22-cv-00011-GFVT ) v. ) ) MEMORANDUM OPINION KENTUCKY JUSTICE AND PUBLIC ) & SAFETY CABINET, DEPARTMENT OF ) ORDER POLICE, et al., ) ) Defendants. ) )

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This matter is before the Court on Plaintiff Michael Webb’s Motion to Amend his Complaint. [R. 18.] Mr. Webb seeks leave to amend because he inadvertently did not amend his complaint during the period in which he was permitted to do so by right. In response, the Defendants urge the Court to deny his motion because they suggest that the amended complaint would not survive a motion to dismiss. The Court will GRANT Mr. Webb’s Motion [R. 18] and allow him to amend to permit further briefing as to whether the amended complaint should be dismissed. I Captain Michael Webb, a Kentucky State Trooper, brought this suit against several Kentucky state officials in their personal capacities pursuant to 42 U.S.C. § 1983. [R. 1.] Mr. Webb served as the Commander of the Recruitment Branch for the Department of State Police. Id. at 3. He believes that the Defendants demoted him because of his presence in Washington, D.C., on January 6, 2021. Id. at 9. According to Mr. Webb, he and his family went to the D.C. area for a sightseeing tour. Id. at 6. While there, his wife made a last-minute decision to attend the rally held outside the capitol. Id. at 7. Mr. Webb claims that neither he nor his family participated in the unrest that followed the rally. Id. at 7–8.

Once back in Kentucky, Mr. Webb found himself the subject of an administrative inquiry and reassigned to a different department. Id. at 8. Eventually, his presence in D.C. made the news, and the Kentucky State Police issued a statement that Mr. Webb was in D.C. but did not enter the capitol. Id. at 10. As a result of his reassignment and allegedly false association with the capitol riots, Mr. Webb claims to suffer from post-traumatic stress, depression, and anxiety. Id. at 11. So, Mr. Webb sued several of the state officials above him for deprivation of his rights protected by the United States and Kentucky constitutions under color of state authority. Id. at 12–13. Beginning on June 8, 2022, the Defendants filed several motions to dismiss the complaint. [E.g., R. 5.] Among other grounds, some defendants claimed protection under

qualified immunity because the complaint did not specify which of Mr. Webb’s constitutional rights were violated. [R. 8-1 at 11.] In response, Mr. Webb stated that he intended to amend his complaint to specify three constitutional rights. [R. 13 at 20.] On November 11, 2022, Mr. Webb filed the instant motion for leave to amend. [R. 18.] As the matter is fully briefed, the issue is ripe for review. [R. 19; R. 20; R. 21.] II The Federal Rules of Civil Procedure allow plaintiffs to amend their complaints either by right or with leave of the Court. Fed. R. Civ. P. 15(a). There are two scenarios where a plaintiff can amend by right. Id. First, the plaintiff can amend his complaint within twenty-one days of serving it. Id. § 15(a)(1)(A). Second, he can amend by right before the earlier of twenty-one days after service of a responsive pleading or twenty-one days after service of a motion under Rule 12(b), (e), or (f). Id. § 15(a)(1)(B). Otherwise, the plaintiff must obtain consent from his opposing party or from the Court to amend a pleading. Id. § 15(a)(2). The Rules direct federal

courts to “freely give leave when justice so requires.” Id. The parties disagree as to whether Mr. Webb is entitled to amend his complaint by right. The Defendants assert that Mr. Webb needs the Court’s leave to amend his complaint and that the Court should analyze the amendment for futility. [R. 19 at 1 (citing Miller v. Calhoun Cty., 408 F.3d 803, 817 (6th Cir. 2005)).] Under that standard, the Court “need not grant leave to amend . . . where amendment would be ‘futile.’” Calhoun Cty., 408 F.3d at 817 (citing Foman v. Davis, 371 U.S. 178, 182 (1962)). Because they argue that the amended complaint would not survive a motion to dismiss, the Defendants ask the Court to deny Mr. Webb’s request to amend his complaint and to grant their pending motions to dismiss. [R. 19 at 4.] On the other hand, Mr. Webb contends that he has an absolute right to amend his

complaint because the Defendants have not filed an answer and because the Court has not ruled on the motions to dismiss. [R. 21 at 1.] Mr. Webb is incorrect because he relies on cases interpreting an outdated version of the Rules of Civil Procedure. Nevertheless, justice requires that he be given leave to amend his complaint. A Mr. Webb’s contention that he has an absolute right to amend his complaint so long as the Defendants have not served an answer and the Court has not decided the pending motions to dismiss is incorrect. [R. 21 at 1.] Mr. Webb relies on a rule from the District of Columbia Circuit Court of Appeals that “Rule 15(a) ‘guarantees a plaintiff an absolute right’ to amend the complaint once at any time so long as the defendant has not served a responsive pleading and the court has not decided a motion to dismiss.” Anderson v. USAA Cas. Ins. Co., 218 F.R.D. 307, 309 (D.D.C. 2003) (quoting James v. Hurson Assocs., Inc. v. Glickman, 229 F.3d 277, 282–83 (D.C. Cir. 2000)). Under a previous version of the Rules, Rule 15(a) stated “[a] party may

amend the party’s pleading once as a matter of course at any time before a responsive pleading is served . . . .” Hurson Assocs., 229 F.3d at 283 (citing Fed. R. Civ. P. 15(a)). Where the plaintiff asked to amend a complaint, courts interpreted the term “responsive pleading” to refer to the answer. 6 Charles Alan Wright & Arthur R. Miller, Federal Practice and Procedure § 1483 (3d ed. 2022). The filing of a motion to dismiss did not prevent a plaintiff from amending the complaint without the leave of the court. Id. Now, Rule 15(a) states that “[a] party may amend its pleading once as a matter of course . . . 21 days after service of a responsive pleading or 21 days after service of a motion under Rule 12(b) . . . .” Fed. R. Civ. P. 15(a). The Rule was revised in 2009 to clarify the deadline by which a pleading could be amended by right. Wright & Miller, supra, § 1483. The Committee intended

the change to encourage “the pleader to consider carefully and promptly the wisdom of amending to meet the arguments” in a motion to dismiss. Id. (quoting Committee Note to the 2009 amendment to Rule 15). Accordingly, a plaintiff’s period in which he may amend a complaint by right can now terminate twenty-one days after the filing of a motion to dismiss. Id. Here, Mr. Webb filed his motion to amend the complaint one-hundred-fifty-six days after the filing of the first motion to dismiss. [R. 5; R. 18.] Mr. Webb explains that “his counsel prepared [the] amendment to the Complaint, believing it to have been filed by [his] counsel’s staff simultaneous[ly] with the Response to the various motions to dismiss.” [R. 18 at 1.] So, the issue is not whether Mr. Webb could amend his complaint by right. He could not. Instead, the Court must decide whether justice requires it to permit Mr.

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Related

Foman v. Davis
371 U.S. 178 (Supreme Court, 1962)
James v. Hurson Associates, Inc. v. Glickman
229 F.3d 277 (D.C. Circuit, 2000)
Douglas Estes v. Kentucky Utilities Company
636 F.2d 1131 (Sixth Circuit, 1980)
Anderson v. USAA Casualty Insurance
218 F.R.D. 307 (District of Columbia, 2003)

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Webb v. Kentucky Justice and Public Safety Cabinet, Department of State Police, Counsel Stack Legal Research, https://law.counselstack.com/opinion/webb-v-kentucky-justice-and-public-safety-cabinet-department-of-state-kyed-2023.