Case Explained: Shapiro v. Campanelli

Court: United States Court of Appeals for the Tenth Circuit

Filed: 2026-07-08

Docket: 4:25-CV-00679-SEH-CDL)

The Tenth Circuit reversed the district court’s dismissal of a pro se prisoner’s complaint and remanded the case for further proceedings. The court held that while the plaintiff’s single-paragraph complaint alleging a Fourteenth Amendment conspiracy was insufficient to state a claim under *Bell Atlantic Corp. v. Twombly*, the district court erred by dismissing the case without prejudice without explaining why granting the plaintiff leave to amend would be futile. Under 28 U.S.C. § 1915(e)(2)(B)(ii), dismissal is proper only when it is obvious that the plaintiff cannot prevail and amendment would be futile; because the district court failed to provide a justification for denying an opportunity to cure the pleading deficiencies, the refusal to grant leave was not a valid exercise of discretion. The practical consequence is that the district court must now either permit the plaintiff to amend his complaint or explicitly explain why such amendment would be futile. Additionally, the court admonished the plaintiff for failing to adhere to Federal Rules of Appellate Procedure 28 and Tenth Circuit Local Rules in his one-sentence appeal brief.

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