Lin v. District of Columbia
Civil Action No. 2016-0645
| D.D.C. | Oct 19, 2016Background
- Plaintiff Xingru Lin sued the District of Columbia and others alleging police misconduct after an incident at her Chinatown bus company where officers sided with a nonpaying would‑be customer, allegedly used excessive force, and failed to provide a Chinese‑speaking officer.
- Lin moved for leave to file an amended/supplemental complaint to add allegations about three additional incidents (one pre‑suit, two post‑suit) involving MPD interactions at the same workplace over roughly five months.
- Lin argued consolidation promotes judicial economy by resolving related incidents in one case; D.C. opposed, contending the new incidents were distinct and unrelated.
- The Court treated the filing as both an amendment (Rule 15(a)) and a supplement (Rule 15(d)) and applied the same liberal standard for leave to amend/supplement.
- The District did not argue futility, prejudice, or delay; discovery had not begun and the Court saw no apparent prejudice from consolidation.
- The Court found the new allegations sufficiently connected to the original complaint (common location, similar claims about lack of Chinese‑speaking officers, alleged police mishandling, and alleged retaliation) and granted leave to amend/supplement; the Court denied without prejudice the pending motion to partially dismiss and set response/deadline dates.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether leave to amend/supplement should be granted under Rules 15(a)/15(d) | Lin: incidents are related; consolidating promotes judicial economy | D.C.: new incidents are distinct and unrelated to original claims | Granted; leave freely given absent futility/prejudice and sufficient factual connection exists |
| Whether the supplemental allegations must "connect" to the original pleading | Lin: supplemental events arise from same setting and policies (MPD Chinatown inattention, language access) | D.C.: lack of factual nexus among incidents | Court: connection sufficient (shared time frame, location, similar legal grievances, alleged retaliation) |
| Whether granting leave would prejudice defendant or delay case | Lin: consolidation efficient; no prejudice asserted | D.C.: argued only distinctness, not prejudice or delay | Court: no prejudice shown; early stage, discovery not started, denial might cause duplicate litigation |
| Whether the proposed amendments are futile | Lin: claims plausible and nonfutile | D.C.: did not contend futility | Court: no futility argument presented; not a basis to deny leave |
Key Cases Cited
- Hall v. C.I.A., 437 F.3d 94 (D.C. Cir. 2006) (distinguishes amendment under Rule 15(a) from supplementation under Rule 15(d))
- Wildearth Guardians v. Kempthorne, 592 F. Supp. 2d 18 (D.D.C. 2008) (motions to amend and to supplement are subject to the same standard)
- Willoughby v. Potomac Elec. Power Co., 100 F.3d 999 (D.C. Cir. 1996) (leave to amend should be freely given absent good reason)
- Aftergood v. C.I.A., 225 F. Supp. 2d 27 (D.D.C. 2002) (supplemental pleading should connect to the original pleading)
- Quaratino v. Tiffany & Co., 71 F.3d 58 (2d Cir. 1995) (discusses connection requirement for supplemental pleadings)