Mary Martha McComas v. United States District Court for the District of Oregon

Whether when denying a pro se litigant leave to amend the complaint, a district court must provide a reason for that denial (as held by the Third, Seventh, Ninth, Eleventh, and D.C. Circuits), or whether a district court need not provide a justifying reason when denying a pro se litigant leave to amend the complaint if that reason is apparent from an analysis of the record (as held by the First, Fourth, Fifth, and Tenth Circuits.)