Erwin Lejon-Twin El v. Joe Marino, 17-2492

Plaintiff Erwin LeJon‑Twin El (pro se) sued former employer Impax Laboratories, Inc. and its HR director after they issued paychecks under the name on file (his former name) rather than the name he currently uses.
District Court dismissed his initial complaint without prejudice under Rule 12(b)(6); granted leave to amend; El filed an amended complaint but the court later denied further leave and dismissed the case with prejudice as amendment would be futile.
El filed post‑judgment motions (reassignment/disqualification, Rule 60(b)/59(e) reconsideration requests, motion for stay, and other filings); the District Court denied them.
El appealed the denial of leave to amend and the post‑judgment denials; the Third Circuit reviewed denial of leave for abuse of discretion and futility de novo, and post‑judgment rulings for abuse of discretion.
The proposed amended complaint rested largely on statutes and constitutional provisions that apply to government actors or are otherwise inapplicable (e.g., Privacy Act, RLUIPA, §1983, various criminal statutes), and asserted a New Jersey wage‑payment regulation as the only state law claim.
The District Court declined supplemental jurisdiction over the state claim once federal claims failed; the Third Circuit affirmed dismissal and denial of post‑judgment relief as non‑abusive of discretion.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether leave to amend should be allowed	El argued his proposed amended complaint stated federal and state claims based on defendants’ use of his former name for paychecks	Defendants argued they are private actors and the federal statutes El cites do not create a private cause of action	Denied: amendment would be futile because cited federal statutes apply to government actors or are inapplicable; no viable federal claim pleaded
Whether defendants are state actors for §1983/Fourth Amendment purposes	El contended defendants’ conduct implicated federal rights	Defendants argued they are private employer and HR director, not state actors	Denied: defendants are not state actors; §1983 inapplicable
Whether District Court should retain supplemental jurisdiction over state wage‑payment claim	El sought relief under N.J. Admin. Code. 12:55‑2.4	Defendants argued no federal claim exists to support supplemental jurisdiction	Declined: court properly relinquished supplemental jurisdiction after all federal claims dismissed
Whether post‑judgment motions (reassignment/disqualification, Rule 60(b)/59(e), stay) warranted relief	El alleged judicial bias and sought reconsideration/stay	Defendants urged motions were meritless, mere disagreement with rulings, and inapplicable standards	Denied: allegations of bias were baseless; motions were relitigation attempts; stay denied for failure to show likelihood of success or irreparable harm

U.S. ex rel. Schumann v. Astrazeneca Pharm. L.P., 769 F.3d 837 (3d Cir. 2014) (standard of review for leave to amend/futility)
Bronowicz v. Allegheny Cty., 804 F.3d 338 (3d Cir. 2015) (pleading standard—construing facts in plaintiff's favor)
Shane v. Fauver, 213 F.3d 113 (3d Cir. 2000) (grounds to deny leave to amend, including futility)
Lazaridis v. Wehmer, 591 F.3d 666 (3d Cir. 2010) (abuse of discretion standard for post‑judgment motions)
Budget Blinds, Inc. v. White, 536 F.3d 244 (3d Cir. 2008) (reconsideration standards)
Imprisoned Citizens Union v. Ridge, 169 F.3d 178 (3d Cir. 1999) (stay standards)
Cox v. Horn, 757 F.3d 113 (3d Cir. 2014) (abuse of discretion components)
Benn v. Universal Health Sys., Inc., 371 F.3d 165 (3d Cir. 2004) (private actors vs. state actors analysis for §1983)
Republic of Philippines v. Westinghouse Elec. Corp., 949 F.2d 653 (3d Cir. 1991) (factors for stay pending appeal)
Blystone v. Horn, 664 F.3d 397 (3d Cir. 2011) (limits on motions for reconsideration)
In re Imperial "400" Nat., Inc., 391 F.2d 163 (3d Cir. 1968) (motion under Rule 60(b) not a substitute for appeal)
In re U.S. Healthcare, Inc., 193 F.3d 151 (3d Cir. 1999) (when caption errors do not require remand)
Fletcher‑Harlee Corp. v. Pote Concrete Contractors, Inc., 482 F.3d 247 (3d Cir. 2007) (waiver of arguments not raised below)
Gov’t of Virgin Islands v. Mills, 634 F.3d 746 (3d Cir. 2011) (liberal construction of pro se notices of appeal)