Dist. Ct. did not err in dismissing as untimely plaintiff’s libel claim, alleging that defendant posted on websites certain defamatory statements indicating that plaintiff was “scam and fraud” and “stole money,” even though defendant had updated one posting that was within relevant one-year limitations period. While pro se plaintiff argued that Dist. Ct. improperly failed to offer him opportunity to amend his libel claim and to advise him on how to do so, Rule 15(a)(2) does not require Dist. Ct. to offer parties legal guidance on how to amend their pleadings, since such requirement would force Dist. Ct. to go outside their roles as neutral judges. Ct. further found that updating untimely 2011 posting with timely 2015 post, without changing content of 2011 post, was insufficient to escape “single-publishing” rule that precludes plaintiff from alleging timely defamation claim, since 2015 posting related back to 2011 posting.
Federal 7th Circuit Court
Civil Court
Libel