Wade Reeves, appearing pro se, filed a lawsuit in the Northern District of Oklahoma alleging constitutional violations by state officials in California and Oklahoma related to child support proceedings. Reeves sought injunctive and declaratory relief against these officials. The defendants moved to dismiss under Federal Rule of Civil Procedure 12(b)(6). The district court granted the motions, ruling that Reeves' complaint did not comply with Rule 8(a)(2) because it scattered and concealed the few allegations that mattered in a morass of irrelevancies. The court dismissed the case without prejudice but closed the case file. Two weeks later, Reeves filed an amended complaint without obtaining leave to do so, which the district court struck from the docket. Reeves then moved for relief from the judgment to reopen the case and grant leave to amend, and also sought sanctions against defense counsel. The district court denied all these requests, leading to this appeal.
The Tenth Circuit reviewed the dismissal for an abuse of discretion, noting that while pro se pleadings are liberally construed, the court does not act as the litigant's advocate. The court applied the standard that a plaintiff satisfies Rule 8(a)(2) only if they provide a short and plain statement showing entitlement to relief. The court found that Reeves' allegations were extraordinarily broad, not directed at any particular defendant, and included over 40 pages of exhibits without sufficient explanation of their relevance. The court cited Mann v. Boatright, stating it is not the district court's job to stitch together cognizable claims from a wholly deficient pleading. Regarding the denial of leave to amend, the court noted that where a plaintiff fails to request leave to amend in response to a motion to dismiss, the district court does not abuse its discretion by dismissing without sua sponte granting leave. On the post-judgment relief, the court reviewed the denial of the motion to alter or amend the judgment for abuse of discretion. The district court found amendment would be futile because the proposed amended complaint still consisted of unexplained, conclusory statements and failed to explain the relevance of over 100 pages of exhibits. The court also affirmed the striking of the amended complaint because Reeves filed it after dismissal without first moving to reopen the case under Rule 59(e) or 60(b) and then seeking leave to amend under Rule 15. Finally, the court noted that Reeves waived any argument regarding Rule 11 sanctions because he failed to comply with the pre-filing service requirements of Rule 11(c)(2).
The judgment of the district court stands, denying Reeves' request for injunctive or declaratory relief against state officials regarding child support proceedings. The decision reinforces that pro se litigants must still adhere to the basic pleading requirements of Rule 8(a)(2) and cannot rely on the court to construct their claims. It also clarifies that a plaintiff must follow the proper procedural steps to reopen a closed case and seek leave to amend after dismissal, rather than filing an amended complaint directly. The ruling leaves open the question of whether Reeves could have succeeded had he properly pleaded his claims, but confirms that the current pleading deficiencies were fatal.