Williams v. Citigroup Inc.

Linda Williams (plaintiff) developed a new structure for issuing airline facility bonds; Citigroup (defendant), an underwriter, declined to use it. Williams sued Citigroup and others for antitrust conspiracy, and the district court dismissed for failure to state a plausible claim and entered judgment. Williams moved post-judgment for reconsideration and for leave to amend her complaint; the district court denied it in a brief order saying such a motion must be filed in the first instance. Williams appealed.

Whether courts should freely grant leave to amend a complaint when justice so requires under Rule 15(a) even after a judgment has been entered.