Robert Lassiter v. City of Philadelphia, 716 F.3d 53

Lassiter filed a 2011 complaint alleging Fourth Amendment violations arising from a May 22, 2009 incident.
Defendants answered on August 2, 2011 and did not raise a statute of limitations defense in the answer.
At a Rule 16 pretrial conference on September 20, 2011, the district court observed the limitations issue and invited briefing.
Defendants moved to amend their answer; the district court granted the motion on February 23, 2012 over Lassiter's opposition.
Defendants then moved for judgment on the pleadings; the district court dismissed the complaint as time-barred on May 29, 2012.
Lassiter appealed, challenging the district court's sua sponte handling of the statute of limitations issue.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the district court could raise the statute of limitations sua sponte at Rule 16	Lassiter argued the court erred by raising the limitation defense sua sponte	District court has authority to manage pretrial issues and raise such defenses	Yes; district court validly raised the issue under Rule 16

Phillips v. Allegheny County, 869 F.2d 234 (3d Cir. 1989) (trial court may actively manage pretrial issues)
Buffington v. Wood, 351 F.2d 292 (3d Cir. 1965) (broad pretrial management power under Rule 16)
Delta Theatres, Inc. v. Paramount Pictures, Inc., 398 F.2d 323 (5th Cir. 1968) (judge may sift issues to expedite trial)
Brinn v. Bull Insular Lines, Inc., 28 F.R.D. 578 (E.D. Pa. 1961) (court may limit theories at pretrial)
Travelers Indem. Co. v. Dammann & Co., Inc., 594 F.3d 238 (3d Cir. 2010) (district court may raise deficiencies with opportunity to respond)
Eriline Co. S.A. v. Johnson, 440 F.3d 648 (4th Cir. 2006) (waivable defenses waived if not raised timely)
Haskell v. Wash. Twp., 864 F.2d 1266 (6th Cir. 1988) (waivable defenses; sua sponte rulings criticized when waivers occur)
Pediatrix Screening, Inc. v. Telechem Int’l, Inc., 602 F.3d 541 (3d Cir. 2010) (pretrial sua sponte raising of affirmative defenses approved with response opportunity)
Highmark, Inc. v. UPMC Health Plan, Inc., 276 F.3d 160 (3d Cir. 2001) (district courts may raise equitable defenses sua sponte within limits)
Charpentier v. Godsil, 937 F.2d 859 (3d Cir. 1991) (failure to raise defenses does not automatically waive them; amendable)
Robinson v. Johnson, 313 F.3d 128 (3d Cir. 2002) (broader latitude to amend pleadings to assert defenses)
Meadow Gold Prods. Co v. Wright, 278 F.2d 867 (D.C. Cir. 1960) (pretrial issue identification to promote efficiency)