Lisa Richardson Henderson v. Showcase Home Improvements, Inc.
June 30, 2026·26-1077·Per Curiam·By Maria Santos
The Fourth Circuit affirmed a district court order denying a pro se plaintiff's motion to reopen a case. The court held that the motion was properly treated as a Rule sixty point B motion because it was filed more than twenty-eight days after the dismissal order.
Lisa Richardson Henderson, proceeding pro se, appealed a district court order denying her motion to reopen. She sought to file a second amended complaint after the district court had dismissed her amended complaint pursuant to Section nineteen hundred fifteen, subsection E, paragraph two, subsection B of Title twenty-eight of the United States Code.
The court’s reasoning
The court determined that because the motion to reopen was filed more than twenty-eight days after the entry of the dismissal order, it must be analyzed as a motion under Rule sixty point B of the Federal Rules of Civil Procedure. The court noted that when a plaintiff seeks to reopen a case under Rule sixty point B to file an amended complaint, she must satisfy one of the Rule sixty point B grounds. Upon review, the court concluded that the district court did not abuse its discretion in denying the motion.
What it means going forward
The decision reinforces the strict timing requirements for pro se litigants seeking to amend complaints after dismissal, requiring them to meet Rule sixty point B standards if they miss the initial window for reopening.
