Lumumba v. Pierce County, 3:25-cv-05381

Plaintiff Francisca Ajai Ndeta Lumumba, proceeding pro se, filed a civil rights lawsuit alleging excessive force and failure to provide adequate medical care during her arrest and detention in Pierce County Jail.
Ms. Lumumba's complaints included constitutional violations and claims under the ADA, Rehabilitation Act, HIPAA, and various Washington statutes.
She filed a motion for leave to submit a supplemental complaint adding new factual allegations and additional statutory causes of action.
The supplemental complaint added further factual details about her medical condition and the alleged conduct of the defendants.
Defendants did not oppose the motion to supplement, and the case was still at an early stage in proceedings.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether plaintiff should be allowed to supplement complaint	Seeks to add facts and claims for complete adjudication	None (not opposed)	Granted; supplementation allowed to ensure full adjudication

Eminence Cap., LLC v. Aspeon, Inc., 316 F.3d 1048 (9th Cir. 2003) (leave to amend pleadings should be applied with "extreme liberality")
Foman v. Davis, 371 U.S. 178 (1962) (court must justify denial of leave to amend)
Chudacoff v. Univ. Med. Ctr. of S. Nev., 649 F.3d 1143 (9th Cir. 2011) (motions to amend should be denied only for bad faith, futility, or prejudice)
Webb v. United States, 655 F.2d 977 (9th Cir. 1981) (amendments should facilitate decision on merits over technicalities)
Erickson v. Pardus, 551 U.S. 89 (2007) (pro se pleadings construed liberally and held to less stringent standards)