Siguel v. King Farm Citizens Assembly, Inc., 8:22-cv-00672

Plaintiff Edward Siguel, proceeding pro se, sued King Farm Citizens Assembly, Inc. (KFCA), individual board members, architectural firm BFMA, and attorney Ursula Burgess, alleging violations of the Fair Housing Act (FHA), Americans with Disabilities Act (ADA), and other laws related to housing modifications and accommodations.
Siguel claimed improper denial of requests for modifications (roof balcony, sheds, patio, trellis), discrimination, retaliation, and other unlawful conduct by the HOA and its affiliates.
The Court previously granted in part, dismissed in part the First Amended Complaint, allowing only the claim regarding storage sheds on the front porch and back of the house to proceed against KFCA and BFMA; most other counts were dismissed.
Siguel filed a motion for reconsideration, attaching new documents and arguments, essentially claiming error in the court’s prior order and seeking to relitigate issues and introduce additional material.
Defendants generally opposed, arguing no basis for reconsideration, and some (BFMA) tried to relitigate issues themselves or strike the motion; Burgess focused on her qualified immunity.
The Court, following Fourth Circuit law, evaluated the reconsideration motion under the standards for interlocutory orders, requiring new evidence, change in law, or clear error causing manifest injustice.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether reconsideration is warranted based on new evidence	Siguel argued new documents clarify and support his claims, and that prior factual/legal errors exist.	Defendants argued there was no new evidence, just rehashed or newly presented material already available or irrelevant.	No new evidence arising after prior order justified reconsideration.
Whether a change in law warrants revisiting the prior order	Siguel claimed the law was ignored or misapplied and asked the court to revisit its interpretation.	Defendants argued no relevant law has changed and prior legal analysis stands.	No change in law or supervening authority justified reconsideration.
Whether clear error or manifest injustice occurred in the prior order	Siguel claimed the Court’s decision was clearly erroneous and caused injustice.	Defendants argued the Court’s application of law and analysis were proper; disagreement is not grounds for reconsideration.	No clear error or manifest injustice found.
Whether Defendants’ other arguments (Burgess privilege/BFMA shed claim) warranted reconsideration of dismissal denials	Defendants pressed for further dismissal on privilege or legal interpretation grounds.	Plaintiff generally opposed, reiterating his claims.	Court declined to reconsider its prior partial denial of dismissal.

Ashcroft v. Iqbal, 556 U.S. 662 (2009) (sets pleading standards for plausibility in Rule 12(b)(6) motions)
Bell Atl. Corp. v. Twombly, 550 U.S. 544 (2007) (pleading must state enough facts to suggest a cognizable claim)
U.S. Tobacco Coop., Inc. v. Big South Wholesale of Va., LLC, 899 F.3d 236 (4th Cir. 2018) (standards for reconsideration of interlocutory orders and law of the case)
Carlson v. Bos. Sci. Corp., 856 F.3d 320 (4th Cir. 2017) (sets standard for revisiting interlocutory orders: new evidence, change in law, clear error)
Am. Canoe Ass’n v. Murphy Farms, Inc., 326 F.3d 505 (4th Cir. 2003) (trial courts have discretion, within limits, to revisit interlocutory orders)