Stanton Square LLC v. City of New Orleans, 2:23-cv-05733

Stanton Square, LLC sought to develop a multi-family housing project called The Village at English Turn in Lower Coast Algiers, New Orleans, on land zoned for such use since the 1980s.
Community opposition, led by residents and the property association of nearby English Turn (a wealthy, primarily white enclave), campaigned strongly against the project, citing concerns over crime and property values, which Stanton alleged were pretextual and motivated by discriminatory intent.
The City Council passed an interim zoning district (IZD) that temporarily halted multi-family developments for impact studies; later, they made downzoning permanent, against City Planning Commission (CPC) recommendations, and changed the properties’ zoning to single-family residential.
Stanton Square filed suit against the City, the City Council, and a councilmember, seeking, among other remedies, dissolution of the IZD and claiming violations of federal and Louisiana law.
Procedurally, the case was at the stage of ruling on Stanton's motion for leave to file a Second Amended Complaint, seeking to add new claims (inverse condemnation) and two additional plaintiffs due to the permanent downzoning.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Leave to amend to add takings claim after deadline	Permanent downzoning now makes claim ripe; could not have asserted earlier.	Amendment futile; no viable takings claim—property not fully deprived of use.	Allowed. Good cause shown; amendment not clearly futile.
Addition of new plaintiffs after deadline	Related properties now affected; same ownership and impact.	Too late; no good cause; no injury or standing shown for new entities.	Denied. No good cause; prejudicial at late stage.
Futility of amendment (inverse condemnation)	Permanent regulatory action has severely harmed property value; viable claim.	Property not entirely deprived of use; amendment futile.	Amendment not futile; merits not resolved at this stage.
Prejudice or delay from amendment	No undue prejudice; trial set far off; discovery ongoing.	Prejudicial to add new parties, theories, and claims now.	No prejudice for adding claim; but denied parties.

U.S. Bank Nat. Ass'n v. Filgueira, 734 F.3d 420 (5th Cir. 2013) (standard for modifying scheduling orders under Rule 16)
S & W Enters., L.L.C. v. Southtrust Bank of Ala., NA, 315 F.3d 533 (5th Cir. 2003) (factors for post-deadline amendments)
Foman v. Davis, 371 U.S. 178 (1962) (standards for granting leave to amend under Rule 15)
Avatar Exploration, Inc. v. Chevron USA, Inc., 933 F.2d 314 (5th Cir. 1991) (leave to amend not automatic—even under Rule 15 bias)
Gregory v. Mitchell, 634 F.2d 199 (5th Cir. 1981) (balancing party’s right to amend against court’s need for orderly process)
Stripling v. Jordan Prod. Co., 234 F.3d 863 (5th Cir. 2000) (futility of amendment—motion to dismiss standard)
Annison v. Hoover, 517 So.2d 420 (La. App. 1st Cir. 1987) (regulatory takings under Louisiana law)