Uwasomba v. Henrico County Department of Social Services, 3:24-cv-00405

Chidimma Uwasomba, proceeding pro se, brought suit against Henrico Department of Social Services (DSS) alleging violation of her Fourteenth Amendment rights relating to the removal of her children and allegedly fabricating misleading information in court.
The original complaint was filed on May 31, 2024; several amended complaints followed, with redactions required to protect minors’ information.
Henrico DSS moved to dismiss the complaint, and after briefing from both sides, the District Court granted the motion and dismissed the Second Amended Complaint with prejudice on November 19, 2024.
Uwasomba subsequently filed a motion for reconsideration, which the Court construed as a Rule 59(e) motion to alter or amend the judgment.
The Court considered the motion under the liberal standards for pro se litigants, but applied the established legal test for reconsideration under Rule 59(e).

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether reconsideration is warranted under Rule 59(e)	DSS violated her rights; old allegations relitigated	No new law, facts, or errors justifying relief	Motion denied; no basis for Rule 59(e) relief

Erickson v. Pardus, 551 U.S. 89 (2007) (liberal construction for pro se filings)
Pacific Ins. Co. v. American National Fire Ins. Co., 148 F.3d 396 (4th Cir. 1998) (Rule 59(e) motions are extraordinary remedies)
Hutchinson v. Staton, 994 F.2d 1076 (4th Cir. 1993) (three grounds for Rule 59(e) relief: intervening law, new evidence, clear error/manifest injustice)
Durkin v. Taylor, 444 F. Supp. 879 (E.D. Va. 1977) (Rule 59(e) not for mere disagreement with the court’s ruling)