Baghirzade v. Armenian National Committee of America
3:24-cv-01077
S.D. Cal.Apr 14, 2025Background
- Plaintiff Aynur Baghirzade, an attorney, filed suit in the Southern District of California against the Armenian National Committee of America and others, advancing federal claims.
- Previous versions of the complaint were dismissed for failure to state a cognizable federal claim; leave to amend was granted but strictly limited to correcting deficiencies in five federal claims only, with explicit instructions not to add new claims or defendants without permission.
- Plaintiff was repeatedly reminded by the court of specific procedural requirements, including submitting a redlined copy of any amended complaint, complying with local rules, and using specified formatting (e.g., 14-point font).
- Plaintiff requested and was granted two extensions to file a Third Amended Complaint (TAC), but was advised that no further extensions would be granted.
- The ultimately filed TAC was substantially longer (198 pages vs. 78), used the wrong font size, failed to submit a compliant redline, and added a new defendant (ARF Eastern USA, Inc.) without leave of court.
- The court struck the TAC for noncompliance with clear orders and rules, resulting in dismissal of the action.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Scope of permitted amendment | Claimed added defendant ARF was not new, just a corrected name | Addition of ARF is unauthorized, exceeds scope of leave to amend | Court held addition exceeded permitted amendment scope |
| Requirement to file redline of amendments | Submitted a version highlighting added text but not deletions | Did not submit proper redline showing changes as required | Court found noncompliance with Local Rule 15.1(c) |
| Compliance with formatting/local rules | Filed in 12-point font, contrary to explicit orders | Argued filings failed to comply with font and page limit rules | Court found repeated violations of local rules/orders |
| Repeated deadline extensions and compliance | Sought more time and reconsideration, citing new information | Argued against further extensions due to pattern of noncompliance | Court denied further extensions, struck TAC, dismissed |
Key Cases Cited
- Atchison, Topeka & Santa Fe Ry. v. Hercules, Inc., 146 F.3d 1071 (9th Cir. 1998) (affirmed district courts’ inherent power to manage their docket)
- Christian v. Mattel, Inc., 286 F.3d 1118 (9th Cir. 2002) (district courts can strike filings for failure to comply with local rules)
- Ferdik v. Bonzelet, 963 F.2d 1258 (9th Cir. 1992) (listed factors to consider before dismissing a case for failure to comply with court orders)
- Yourish v. Cal. Amplifier, 191 F.3d 983 (9th Cir. 1999) (public’s interest in expeditious litigation favors dismissal)
