Messiah v. Garcia Lara, 4:22-cv-02616

California inmate Messiah filed suit pro se in 2022 alleging excessive force by correctional officers at Salinas Valley State Prison, naming specific officers as defendants.
The First Amended Complaint added more correctional officers and allegations of exhaustion of administrative remedies, as well as claims about false reporting and failure to intervene.
The Court partially dismissed the First Amended Complaint, notably the false report claims, and dismissed some defendants, but allowed the excessive force and failure to intervene claims to proceed.
Messiah later sought to file a Second Amended Complaint (SAC), now represented by counsel, seeking to add new defendants (Allen, Atchley), revive claims against previously dismissed defendants (Haner, Andaverde), and assert state law claims.
Defendants opposed, arguing the SAC was untimely, prejudicial, and futile regarding some claims and parties.
The Court analyzed the motion under Federal Rules of Civil Procedure 15(a) (leave to amend) and, to the extent necessary, 16(b) (good cause to modify scheduling order).

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether leave to file the SAC should be granted	Sought to add defendants and clarify claims; amendments timely and in good faith, no undue delay or prejudice	SAC untimely under Rule 16(b); amendments would prejudice and are futile as to some claims/defendants	Leave to amend granted; typed SAC accepted as operative complaint
Whether new defendants Allen and Atchley can be added	Sought to name them for supervisory liability	They had no direct involvement; claims untimely/statute of limitations	Claims against Allen/Atchley dismissed with prejudice
Whether Doe defendants can be added at this stage	Attempted to preserve Doe defendants for later identification	Opposed Doe defendants as counsel now knows identities	Doe defendants dismissed without prejudice; amendment allowed within 14 days
Whether state law claims may be added at this stage and would prejudice defendants	Sought to assert new state law claims	Would be prejudicial and confusing, as defense was prepared under federal law	No undue prejudice; state claims permitted at this stage

DCD Programs, Ltd. v. Leighton, 833 F.2d 183 (9th Cir. 1987) (sets factors for granting leave to amend a complaint)
Bowles v. Reade, 198 F.3d 752 (9th Cir. 1999) (leave to amend may only be denied with specific findings)
Eminence Capital, LLC v. Aspeon, Inc., 316 F.3d 1048 (9th Cir. 2003) (prejudice is the key factor when considering leave to amend)
Gillespie v. Civiletti, 629 F.2d 637 (9th Cir. 1980) (discusses treatment of Doe defendants in federal litigation)
C.F. ex rel. Farnan v. Capistrano Unified Sch. Dist., 654 F.3d 975 (9th Cir. 2011) (district courts have broad discretion to permit late amendments to pleadings)