George Kiebala v. Derek Boris, 928 F.3d 680

Plaintiff George Kiebala owned Curvy Road Holdings, a luxury car-share business; defendant Derek Boris was an investor whose car was removed in 2010 and who later posted negative statements online accusing Kiebala of fraud and theft.
Boris posted multiple online complaints from December 2010 through July 2011; a key post appeared July 20, 2011 on RipoffReport and was later marked "Updated" with a July 22, 2015 timestamp though the text was unchanged.
After another round of posts in 2014–2015, Kiebala sued in federal court (diversity) on July 22, 2016 raising libel and other state-law claims; Boris moved to dismiss.
The district court dismissed claims for breach and tortious interference without prejudice (later requiring corporate plaintiffs), dismissed the libel claim as time-barred under Illinois’ one-year defamation statute, and dismissed intentional infliction of emotional distress (IIED) for failure to plead outrageous conduct.
Kiebala appealed only the libel claim, arguing the court should have allowed amendment and that the July 22, 2015 "update" restarted the statute of limitations.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether district court erred by not advising pro se plaintiff to amend libel claim	Kiebala: court should have suggested amendment based on allegations in his amended pleading about a post within the limitations period	Boris: plaintiff chose not to amend; courts are not obligated to coach pro se litigants or propose pleadings	Court: no abuse of discretion; judges need not invent or urge amendments when pro se plaintiff repeatedly declines to seek them
Whether July 22, 2015 "update" of a 2011 RipoffReport post restarted limitations under Illinois law	Kiebala: the "updated" timestamp effectively republished the post in 2015, creating a new actionable publication within one year of suit	Boris: labeling as "updated" without changing content is passive maintenance/republication that does not reset the statute	Court: single-publication rule applies; identical update alone does not restart limitations; libel claim time-barred

Pippen v. NBCUniversal Media, LLC, 734 F.3d 610 (7th Cir.) (single-publication rule applies to internet postings)
Founding Church of Scientology of Washington, D.C. v. American Medical Ass'n, 377 N.E.2d 158 (Ill. App.) (later incidental reprints do not constitute republication restarting limitations)
Blair v. Nevada Landing Partnership, 859 N.E.2d 1188 (Ill. App.) (republication may start new cause only if content is significantly altered or targets a new audience)
Runnion v. Girl Scouts of Greater Chicago and Northwest Indiana, 786 F.3d 510 (7th Cir.) (presumption favoring at least one opportunity to amend pleadings)
Donald v. Cook County Sheriff's Dep't, 95 F.3d 548 (7th Cir.) (courts must construe pro se complaints liberally but not serve as litigant's advocate)
Hamlin v. Vaudenberg, 95 F.3d 580 (7th Cir.) (courts need not fill in all blanks in pro se complaints)