Runnion Ex Rel. Rsunnion v. Girl Scouts of Greater Chicago, 786 F.3d 510

Megan Runnion, deaf, participated in a Girl Scout troop run by Girl Scouts of Greater Chicago and Northwest Indiana; interpreters provided by GS stopped, leading to her troop's disbandment after her mother complained.
Megan alleged discrimination under the Rehabilitation Act, claiming the Girl Scouts failed to provide sign-language interpretation and retaliated by disbanding the troop.
The district court dismissed under Rule 12(b)(6), concluding Megan failed to plead that the GS organization was a recipient of federal funds covered by the Act.
The court dismissed without leave to amend, based on a novel interpretation of Rehabilitation Act coverage and concerns about amendment futility.
Megan sought Rule 59(e) relief and proposed an amended complaint asserting a broader “principally engaged” theory; the district court vacated and later limited amendment to the “as a whole” theory.
On appeal, Megan challenges the district court’s dismissal and its denial of permission to amend to include the “principally engaged” theory; the Seventh Circuit reverses and remands for further proceedings.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Does §794(b)(3)(A)(ii) cover private membership organizations?	Runnion contends GS can be covered if principally engaged in enumerated services.	GS argues private membership groups are categorically exempt unless open to the public.	No categorical exemption; private membership groups can be covered if principally engaged in enumerated services.
Was amendment to plead a viable theory futile at the pre- or post-judgment stage?	Amendment to plead ‘principally engaged’ theory should be permitted.	Amendment would be futile under the district court’s reading of the Act.	Amendment was not futile; the proposed amended complaint plausibly states a claim.
Did the district court err in denying leave to amend after dismissing the original complaint?	Liberal amendment policy requires at least one opportunity to amend after a Rule 12(b)(6) dismissal.	Amendment could be denied for futility; the court properly dismissed.	District court abused its discretion by denying amendment.
What is the effect of the 2009 Rule 15(a)(1) amendment on amendment rights in this context?	The amendment does not convert to a one-shot right; Rule 15(a)(2) remains liberal.	2009 amendment tightens the window for amendments as a matter of course.	The liberal Rule 15(a)(2) standard applies; the amendment rights were not eliminated.

Bell Atlantic Corp. v. Twombly, 550 U.S. 544 (U.S. 2007) (pleading must show plausibility after Twombly/Iqbal)
Ashcroft v. Iqbal, 556 U.S. 662 (U.S. 2009) (pleading standards require plausible claims)
Johnson v. City of Shelby, 135 S. Ct. 346 (U.S. 2014) (threshold dismissal requires fair notice and plausible claims)
Bausch v. Stryker Corp., 630 F.3d 546 (7th Cir. 2010) (liberal amendment policy; abuse if no justification for denial)
Foman v. Davis, 371 U.S. 178 (U.S. 1962) (leave to amend within discretion; denial without reason is abuse)