Antoque v. Hawaii Community Correctional Center, et al.
June 29, 2026·1:24-cv-00134-MWJS-RT·Unpublished·By Aisha Johnson
The Ninth Circuit affirmed the district court's dismissal of a prisoner's civil rights action alleging claims arising during pretrial detention. The appellate panel concluded that the lower court did not abuse its discretion in denying leave to amend the complaint because such amendment would have been futile.
Bernard Kahalehili Antoque, a Hawaii state prisoner, filed a pro se action under Section nineteen eighty-three alleging claims arising during his pretrial detention at the Hawaii Community Correctional Center. The district court dismissed the action and denied Antoque’s motion for leave to amend the complaint. Antoque also moved for the appointment of counsel, which was denied.
The court’s reasoning
The panel reviewed the denial of leave to amend for an abuse of discretion. The court affirmed, concluding that the district court did not abuse its discretion because any amendment to the complaint would have been futile. The panel noted that the district court’s discretion to deny leave to amend is particularly broad where a plaintiff has previously amended the complaint.
What it means going forward
The decision reinforces the standard that leave to amend a complaint may be denied when the amendment would be futile, particularly in cases where the plaintiff has already amended the complaint previously.
