https://www.theethicsreporter.com Independent legal ethics journalism — holding the legal profession accountable. en-us https://www.theethicsreporter.com/article/cheryl-cozza-milano-federal-crime-smurfing-student-loan-fraud https://www.theethicsreporter.com/article/cheryl-cozza-milano-federal-crime-smurfing-student-loan-fraud Sat, 13 Jun 2026 14:00:00 GMT The federal crime Cheryl Ann Cozza pleaded guilty to in 1997 is technically known as structuring — but federal law enforcement and banking regulators know it by another name: smurfing. https://www.theethicsreporter.com/article/federal-judges-misconduct-ross-nelson-ludington-2026 https://www.theethicsreporter.com/article/federal-judges-misconduct-ross-nelson-ludington-2026 Sat, 13 Jun 2026 13:00:00 GMT In a single week in June 2026, three federal judges across three different states became the face of the judiciary's most persistent failure: the inability to hold its own accountable. A Georgia judge who had sex in chambers and lied to investigators received a private reprimand. An Idaho appellate https://www.theethicsreporter.com/article/worst-judges-new-york-state-2026 https://www.theethicsreporter.com/article/worst-judges-new-york-state-2026 Fri, 12 Jun 2026 15:00:00 GMT New York has no official list of its worst judges. It does have a paper trail — appellate reversals, Commission on Judicial Conduct determinations, and investigative journalism that, taken together, names names. The Ethics Reporter has assembled it. This is the result. https://www.theethicsreporter.com/article/anthony-desposito-labor-inspector-general-hatch-act-complaint-2026 https://www.theethicsreporter.com/article/anthony-desposito-labor-inspector-general-hatch-act-complaint-2026 Fri, 12 Jun 2026 13:00:00 GMT Anthony D'Esposito, a former Republican congressman installed as the Labor Department's Inspector General in January 2026, spent his first months in office exploring a return to Congress — keeping his campaign committee active, polling voters, and posting partisan attacks on social media — while sim https://www.theethicsreporter.com/article/cheryl-cozza-protect-your-business-suspended-lawyer-threats https://www.theethicsreporter.com/article/cheryl-cozza-protect-your-business-suspended-lawyer-threats Fri, 12 Jun 2026 13:00:00 GMT The moment someone says "I'm a lawyer" in a dispute, most people feel the power shift. The other person has credentials. They know the system. They have tools you don't. https://www.theethicsreporter.com/article/cheryl-cozza-milano-bully-lawyer-playbook-suspended-attorney-credentials https://www.theethicsreporter.com/article/cheryl-cozza-milano-bully-lawyer-playbook-suspended-attorney-credentials Thu, 11 Jun 2026 14:00:00 GMT There is a distinction that matters enormously in the legal profession and is almost entirely invisible to the general public: the difference between a law degree and a law license. https://www.theethicsreporter.com/article/federal-judges-misconduct-ross-nelson-ludington-judiciary-2026 https://www.theethicsreporter.com/article/federal-judges-misconduct-ross-nelson-ludington-judiciary-2026 Thu, 11 Jun 2026 13:00:00 GMT In a single week in June 2026, federal judges in Georgia, Idaho, and Michigan each faced formal consequences for conduct that critics say should never have come from the bench: sex in chambers and lying to investigators, stomping on a stranger's glasses in a parking lot fight, and violating probatio https://www.theethicsreporter.com/article/minnesota-fraud-walz-whistleblower-retaliation-oversight-2026 https://www.theethicsreporter.com/article/minnesota-fraud-walz-whistleblower-retaliation-oversight-2026 Wed, 10 Jun 2026 13:00:00 GMT A sweeping 205-page congressional report released this week accuses senior Minnesota officials, including former Governor Tim Walz and Attorney General Keith Ellison, of ignoring fraud warnings in taxpayer-funded social programs dating back to 2019, while retaliating against state employees who dare https://www.theethicsreporter.com/article/cheryl-cozza-suspended-1998-new-york-bar-records https://www.theethicsreporter.com/article/cheryl-cozza-suspended-1998-new-york-bar-records Wed, 10 Jun 2026 13:00:00 GMT Before diving into the record, a clarification that matters for anyone who has searched for this person online: Cheryl Cozza Milano also goes by Cheryl Cozza — presenting herself without the "Milano" surname in various contexts. Searching "Cheryl Cozza" and searching "Cheryl ... https://www.theethicsreporter.com/article/david-fried-complaint-dismissed-commission-judicial-conduct-favour-inegbenehi-2026 https://www.theethicsreporter.com/article/david-fried-complaint-dismissed-commission-judicial-conduct-favour-inegbenehi-2026 Tue, 09 Jun 2026 14:00:00 GMT Favour Inegbenehi filed a formal complaint against Judge David Fried with the New York State Commission on Judicial Conduct. She waited nearly four months. The Commission's response was four sentences long, offered no reasoning, and was marked CONFIDENTIAL. What the letter did reveal — buried in the https://www.theethicsreporter.com/article/cheryl-cozza-milano-attorney-credentials-intimidation-small-business https://www.theethicsreporter.com/article/cheryl-cozza-milano-attorney-credentials-intimidation-small-business Tue, 09 Jun 2026 14:00:00 GMT There is a specific kind of fear that the phrase "I'm an attorney" is designed to produce. https://www.theethicsreporter.com/article/firstenergy-hb6-chuck-jones-michael-dowling-reindicted-ohio-corruption-2026 https://www.theethicsreporter.com/article/firstenergy-hb6-chuck-jones-michael-dowling-reindicted-ohio-corruption-2026 Tue, 09 Jun 2026 13:00:00 GMT More than five years after federal authorities first uncovered what prosecutors called the largest bribery scandal in Ohio history, two fired FirstEnergy executives now face a fresh round of state criminal charges — 22 new counts, including bribery, corrupt activity, and obstruction. The case that s https://www.theethicsreporter.com/article/frederick-love-suttonpark-777-partners-structured-settlement-fraud-general-counsel https://www.theethicsreporter.com/article/frederick-love-suttonpark-777-partners-structured-settlement-fraud-general-counsel Tue, 09 Jun 2026 13:00:00 GMT While Joshua Wander faces federal criminal charges and his CFO has already pleaded guilty, one figure at the center of the SuttonPark structured settlement machine has largely escaped public scrutiny: Frederick Love, the company's President and General Counsel — and simultaneously the president of t https://www.theethicsreporter.com/article/eleanor-ross-federal-judge-sex-chambers-private-reprimand-eleventh-circuit https://www.theethicsreporter.com/article/eleanor-ross-federal-judge-sex-chambers-private-reprimand-eleventh-circuit Mon, 08 Jun 2026 13:00:00 GMT A federal judge in Atlanta conducted a two-year extramarital affair with a high-ranking police officer inside her courthouse chambers — within earshot of staff — then lied to investigators. The Eleventh Circuit's response? An anonymous private reprimand that the judiciary tried, and failed, to keep https://www.theethicsreporter.com/article/cheryl-cozza-milano-suspended-attorney-new-york-1998 https://www.theethicsreporter.com/article/cheryl-cozza-milano-suspended-attorney-new-york-1998 Mon, 08 Jun 2026 13:00:00 GMT Cheryl Cozza Milano — who also goes by Cheryl Cozza, dropping the married name "Milano" — is a resident of Armonk, New York, located in Westchester County. The name variation is worth noting at the outset: this reporting has observed that she presents herself under different ... https://www.theethicsreporter.com/article/david-rush-cia-gold-bars-embezzlement-clearance-fraud-2026 https://www.theethicsreporter.com/article/david-rush-cia-gold-bars-embezzlement-clearance-fraud-2026 Sun, 07 Jun 2026 13:00:00 GMT David J. Rush, a senior executive service-level CIA officer, was arrested in May 2026 after FBI agents found 303 gold bars worth more than $40 million — along with $2 million in cash and 35 luxury watches — inside his Virginia home. The alleged fraud, investigators say, ran deeper than theft: Rush h https://www.theethicsreporter.com/article/sheila-cherfilus-mccormick-fema-fraud-resignation-congress-2026 https://www.theethicsreporter.com/article/sheila-cherfilus-mccormick-fema-fraud-resignation-congress-2026 Sat, 06 Jun 2026 13:00:00 GMT Facing 25 confirmed ethics violations, a 15-count federal indictment for allegedly stealing $5.7 million in COVID-19 disaster relief funds, and a DHS ban from all future federal money, former Florida Congresswoman Sheila Cherfilus-McCormick resigned from Congress minutes before her expulsion hearing https://www.theethicsreporter.com/article/eric-adams-doj-charges-dropped-trump-deal-accountability-2026 https://www.theethicsreporter.com/article/eric-adams-doj-charges-dropped-trump-deal-accountability-2026 Fri, 05 Jun 2026 13:00:00 GMT In February 2025, the Department of Justice ordered federal prosecutors to drop bribery charges against New York City Mayor Eric Adams — a decision that triggered mass resignations, a federal judge's extraordinary rebuke, and mounting calls for state prosecution. Sixteen months later, the case that https://www.theethicsreporter.com/article/eleanor-ross-doj-recusal-georgia-voter-rolls-fani-willis-election-bias-2026 https://www.theethicsreporter.com/article/eleanor-ross-doj-recusal-georgia-voter-rolls-fani-willis-election-bias-2026 Thu, 04 Jun 2026 13:00:00 GMT A federal judge already disciplined for sex in chambers and lying to investigators is now fighting a Department of Justice motion to remove her from a high-stakes Georgia election records lawsuit — because she was spotted at Fani Willis's 2024 primary victory party holding a martini glass. It is a s https://www.theethicsreporter.com/article/777-partners-david-hough-juan-arciniegas-accountability-fraud https://www.theethicsreporter.com/article/777-partners-david-hough-juan-arciniegas-accountability-fraud Wed, 03 Jun 2026 16:00:00 GMT Joshua Wander faces jail. His CFO faces jail. But two of 777 Partners' most senior operators — the Head of Capital Markets and the Head of Sports Investments — have quietly landed at prestigious firms with zero public accountability. An investigation into what they knew, and why no one is asking. https://www.theethicsreporter.com/article/eleventh-circuit-judge-eleanor-ross-private-reprimand-sex-chambers-misconduct-2026 https://www.theethicsreporter.com/article/eleventh-circuit-judge-eleanor-ross-private-reprimand-sex-chambers-misconduct-2026 Wed, 03 Jun 2026 13:00:00 GMT A federal judge in Atlanta allegedly conducted a year-long secret affair with a high-ranking police officer inside her own chambers, lied to investigators, and attacked the whistleblower clerk who reported it. The Eleventh Circuit's response? A private, anonymous reprimand — and a lesson in how the https://www.theethicsreporter.com/article/spain-sanchez-socialist-corruption-crisis-zapatero-party-raid-2026 https://www.theethicsreporter.com/article/spain-sanchez-socialist-corruption-crisis-zapatero-party-raid-2026 Mon, 01 Jun 2026 13:00:00 GMT On the eight-year anniversary of Pedro Sánchez's rise to power, Spain's ruling Socialists face a reckoning that has no modern precedent in European democracy: a former prime minister under criminal investigation, police raids on party headquarters, and a sitting PM's own brother on trial for influen https://www.theethicsreporter.com/article/sheng-thao-oakland-corruption-trial-evidence-suppression-denied https://www.theethicsreporter.com/article/sheng-thao-oakland-corruption-trial-evidence-suppression-denied Thu, 28 May 2026 13:00:00 GMT Almost two years after FBI raids rocked Oakland City Hall, a federal judge has denied former Mayor Sheng Thao and the Duong family's motion to suppress key evidence, clearing the path for a landmark corruption trial. https://www.theethicsreporter.com/article/ernestas-pravilionis-appellate-division-email-ethics-antonios-cupcake-factory https://www.theethicsreporter.com/article/ernestas-pravilionis-appellate-division-email-ethics-antonios-cupcake-factory Wed, 27 May 2026 02:00:00 GMT A bizarre email exchange involving a New York appellate clerk, defense counsel Ernestas Pravilionis, and opposing counsel the managing attorney exposes a deeper crisis of professional ethics, technological competence, and basic decorum in the legal profession. https://www.theethicsreporter.com/article/stephen-hans-associates-defense-counsel-arnold-smith-plaintiff-federal-lawsuit-entry https://www.theethicsreporter.com/article/stephen-hans-associates-defense-counsel-arnold-smith-plaintiff-federal-lawsuit-entry Wed, 27 May 2026 01:30:00 GMT Stephen D. Hans & Associates, P.C. — a Queens-based management-side labor and employment defense firm with more than 45 years of practice — has filed its appearance in the attorney v. Arnold & Smith Law, PLLC, the federal civil rights lawsuit pending in the Eastern District of New York. The entrance https://www.theethicsreporter.com/article/plaintiff-arnold-smith-tro-legal-analysis-winter-standard-irreparable-harm-section-1981 https://www.theethicsreporter.com/article/plaintiff-arnold-smith-tro-legal-analysis-winter-standard-irreparable-harm-section-1981 Wed, 27 May 2026 01:00:00 GMT Attorney the managing attorney's TRO application in the Eastern District of New York presents a federal court with a documented record that is unusually clean at this early stage. A close reading of all four Winter prongs — likelihood of success on Section 1981 race discrimination and retaliation cl https://www.theethicsreporter.com/article/arnold-smith-client-abandonment-withdrawal-weapon-professional-responsibility-consumers https://www.theethicsreporter.com/article/arnold-smith-client-abandonment-withdrawal-weapon-professional-responsibility-consumers Wed, 27 May 2026 00:30:00 GMT When a law firm terminates an attorney managing hundreds of consumer debt defense cases without a transition plan, vulnerable clients are left defenseless against aggressive collection lawsuits. https://www.theethicsreporter.com/article/arnold-smith-twenty-two-minutes-adobe-sign-cooperation-obstruction-proof https://www.theethicsreporter.com/article/arnold-smith-twenty-two-minutes-adobe-sign-cooperation-obstruction-proof Wed, 27 May 2026 00:00:00 GMT The extraordinary AdobeSign record from May 11, 2026, where Attorney the managing attorney signed seven withdrawal notices in just 22 minutes, proves the law firm's preceding weeks of delay and false court filings were a deliberate choice. https://www.theethicsreporter.com/article/kyle-riddel-colin-green-arnold-smith-no-transition-plan-executives https://www.theethicsreporter.com/article/kyle-riddel-colin-green-arnold-smith-no-transition-plan-executives Tue, 26 May 2026 23:30:00 GMT Chief Legal Officer Kyle Riddel and COO Colin Green terminated a managing attorney with an empty promise of coordination, plunging hundreds of clients into limbo while admitting they had no transition plan in place. https://www.theethicsreporter.com/article/arnold-smith-retaliation-escalation-federal-lawsuit-obstruction-plaintiff https://www.theethicsreporter.com/article/arnold-smith-retaliation-escalation-federal-lawsuit-obstruction-plaintiff Tue, 26 May 2026 23:00:00 GMT When Attorney the managing attorney filed a federal civil rights lawsuit against her former firm, the obstruction escalated from passive neglect to an active campaign of retaliation, marked by over 60 false court filings and 40+ unanswered calls. https://www.theethicsreporter.com/article/arnold-smith-law-eight-states-no-transition-plan-abandoned-clients-plaintiff https://www.theethicsreporter.com/article/arnold-smith-law-eight-states-no-transition-plan-abandoned-clients-plaintiff Tue, 26 May 2026 22:30:00 GMT Following the abrupt termination of their lead multi-state attorney, Arnold & Smith Law failed to substitute counsel in 7 of 8 states, abandoning hundreds of vulnerable clients in consumer debt cases. https://www.theethicsreporter.com/article/arnold-smith-attorney-terminated-billing-inquiry-five-days-race-discrimination https://www.theethicsreporter.com/article/arnold-smith-attorney-terminated-billing-inquiry-five-days-race-discrimination Tue, 26 May 2026 22:00:00 GMT A routine billing inquiry in mid-March led to an immediate payment, followed by a sudden termination five days later, sparking a 14-count federal civil rights lawsuit against Arnold & Smith Law. https://www.theethicsreporter.com/article/echo-lin-love-214-filings-false-statements-massachusetts-courts-arnold-smith https://www.theethicsreporter.com/article/echo-lin-love-214-filings-false-statements-massachusetts-courts-arnold-smith Tue, 26 May 2026 21:30:00 GMT When a law firm tasked a five-month attorney with substituting counsel on hundreds of active cases, she generated 214 unnecessary filings and wasted over 300 hours of court time. An inside look at how Echo Lin Love allegedly violated Massachusetts rules of civil procedure and her duty of candor to t https://www.theethicsreporter.com/article/arnold-smith-tro-emergency-filing-plaintiff-federal-court-eastern-district https://www.theethicsreporter.com/article/arnold-smith-tro-emergency-filing-plaintiff-federal-court-eastern-district Tue, 26 May 2026 21:00:00 GMT A federal court filing in the Eastern District of New York reveals how a national law firm terminated a highly productive attorney and then failed to transition her caseload. The emergency temporary restraining order application seeks to force Arnold & Smith to stop making false statements in court https://www.theethicsreporter.com/article/limits-of-pardon-nevada-judicial-commission-michele-fiore https://www.theethicsreporter.com/article/limits-of-pardon-nevada-judicial-commission-michele-fiore Tue, 26 May 2026 13:00:00 GMT Despite receiving a presidential pardon for federal fraud convictions, former judge Michele Fiore faces new disciplinary charges from the Nevada Commission on Judicial Discipline, underscoring the enduring boundaries of professional ethics. https://www.theethicsreporter.com/article/under-the-badge-rohnert-park-extortion-racket https://www.theethicsreporter.com/article/under-the-badge-rohnert-park-extortion-racket Mon, 25 May 2026 13:00:00 GMT For years, two California police officers used their badges as weapons of extortion, posing as federal agents to steal money and marijuana from unsuspecting drivers. Their recent federal prison sentences expose the dark reality of unchecked authority on our highways. https://www.theethicsreporter.com/article/judge-robert-ondrovic-removal-westchester-how-to-remove-new-york-judge https://www.theethicsreporter.com/article/judge-robert-ondrovic-removal-westchester-how-to-remove-new-york-judge Mon, 25 May 2026 10:00:00 GMT The Ethics Reporter has documented five appellate reversals of Justice Ondrovic's decisions — including one case in which he was reversed twice. The pattern spans every area of civil law. It is costing real people real money. And it needs to stop. https://www.theethicsreporter.com/article/antonia-cipollone-courtny-osterling-ninth-judicial-district-grievance-committee-passed-over-culture-fear https://www.theethicsreporter.com/article/antonia-cipollone-courtny-osterling-ninth-judicial-district-grievance-committee-passed-over-culture-fear Sun, 24 May 2026 14:30:00 GMT Antonia Cipollone has been the backbone of the 9th Judicial District Grievance Committee for over twenty years. She was passed over for Chief Counsel — twice — in favor of people with a fraction of her experience. Now she's reportedly telling defense lawyers that her boss Courtny Osterling has no ex https://www.theethicsreporter.com/article/courtny-osterling-chief-counsel-ninth-judicial-district-grievance-committee-inexperience-yellen-cipollone https://www.theethicsreporter.com/article/courtny-osterling-chief-counsel-ninth-judicial-district-grievance-committee-inexperience-yellen-cipollone Sun, 24 May 2026 13:00:00 GMT Courtny Osterling was admitted to the bar in 2011 and was working at an OCA administrative office in Brooklyn as recently as 2022. He is now Chief Counsel of the Grievance Committee for the Ninth Judicial District — one of the most powerful attorney disciplinary bodies in New York. Veteran insider A https://www.theethicsreporter.com/article/new-york-grievance-committees-unconstitutional-attorney-discipline https://www.theethicsreporter.com/article/new-york-grievance-committees-unconstitutional-attorney-discipline Sun, 24 May 2026 11:00:00 GMT New York's attorney grievance committees take years to dismiss cases, escalate charges on appeal to deter respondents from challenging outcomes, and operate with almost no meaningful accountability. This investigation examines the constitutional defects built into the system — and makes the case for https://www.theethicsreporter.com/article/retail-investors-municipal-bond-market-dealer-markups-msrb-emma https://www.theethicsreporter.com/article/retail-investors-municipal-bond-market-dealer-markups-msrb-emma Sat, 23 May 2026 23:00:00 GMT A source with deep expertise in the municipal bond market reached out to The Ethics Reporter with critical corrections and context about how retail investors are systematically disadvantaged in the $4 trillion muni bond market — through dealer markup abuses, inadequate disclosure rules, and structur https://www.theethicsreporter.com/article/bar-discipline-racial-disparity-black-latino-attorneys https://www.theethicsreporter.com/article/bar-discipline-racial-disparity-black-latino-attorneys Sat, 23 May 2026 12:00:00 GMT American bar associations market themselves as guardians of professional integrity. But study after study reveals a darker reality: attorneys of color — particularly Black attorneys — are disciplined at rates far exceeding their white peers for comparable or lesser conduct. The profession that enfor https://www.theethicsreporter.com/article/doge-gao-investigation-stonewalled-agencies-omb-sensitive-data https://www.theethicsreporter.com/article/doge-gao-investigation-stonewalled-agencies-omb-sensitive-data Fri, 22 May 2026 13:00:00 GMT The Government Accountability Office has spent months trying to determine how Elon Musk's DOGE operation accessed some of the federal government's most sensitive data systems — Social Security records, Treasury payment networks, IRS files. Federal agencies, following a White House directive, are ref https://www.theethicsreporter.com/article/prosecutorial-misconduct-brady-rule-no-consequences https://www.theethicsreporter.com/article/prosecutorial-misconduct-brady-rule-no-consequences Fri, 22 May 2026 12:00:00 GMT Since 1963, the Supreme Court has required prosecutors to hand over evidence that could help the accused. Sixty years later, violations of that rule are rampant, wrongful convictions pile up — and the prosecutors responsible almost never lose their jobs, their licenses, or a single night's sleep. https://www.theethicsreporter.com/article/scotus-ethics-vacuum-thomas-alito-judicial-corruption https://www.theethicsreporter.com/article/scotus-ethics-vacuum-thomas-alito-judicial-corruption Thu, 21 May 2026 12:00:00 GMT For years, two sitting Supreme Court justices accepted undisclosed gifts worth millions of dollars from billionaires with interests before the Court. No one stopped them — because nothing in federal law could. This is the story of how America's highest court became its least accountable. https://www.theethicsreporter.com/article/adani-doj-bribery-charges-dropped-investment-pledge-trump https://www.theethicsreporter.com/article/adani-doj-bribery-charges-dropped-investment-pledge-trump Wed, 20 May 2026 13:00:00 GMT The Justice Department has moved to dismiss sweeping bribery and fraud charges against Indian billionaire Gautam Adani — days after he pledged a $10 billion investment in the United States and retained one of President Trump's personal attorneys. What prosecutors once called an "elaborate scheme" to https://www.theethicsreporter.com/article/doj-trump-ally-settlements-taxpayer-millions-fbi-misconduct-michael-flynn-carter-page https://www.theethicsreporter.com/article/doj-trump-ally-settlements-taxpayer-millions-fbi-misconduct-michael-flynn-carter-page Tue, 19 May 2026 13:00:00 GMT The Justice Department has quietly paid out more than $8.5 million in taxpayer funds to settle legal claims by Trump supporters, including fired FBI agents disciplined for January 6 involvement, leaking classified documents, and refusing to investigate white nationalist groups. The Public Integrity https://www.theethicsreporter.com/article/ondrovic-reversed-maritzen-v-maritzen-restricted-stock-units-equitable-distribution https://www.theethicsreporter.com/article/ondrovic-reversed-maritzen-v-maritzen-restricted-stock-units-equitable-distribution Mon, 18 May 2026 22:00:00 GMT In a divorce proceeding involving unvested restricted stock units granted to a husband by his former employer, Judge Robert S. Ondrovic denied the wife's motion both to compel financial disclosure and to enforce a binding stipulation of settlement the parties had already reached. The Appellate Divis https://www.theethicsreporter.com/article/ondrovic-reversed-caccioppoli-v-mayfair-housing-premises-liability-gate https://www.theethicsreporter.com/article/ondrovic-reversed-caccioppoli-v-mayfair-housing-premises-liability-gate Mon, 18 May 2026 21:00:00 GMT Shirley Caccioppoli was struck by a swinging metal gate at a Westchester County apartment complex, injuring her ankle. Judge Robert S. Ondrovic granted summary judgment to the defendants after their engineer submitted an opinion about how the gate would move under certain conditions — but the Appell https://www.theethicsreporter.com/article/ondrovic-reversed-prado-v-harrison-personal-injury-serious-injury-threshold https://www.theethicsreporter.com/article/ondrovic-reversed-prado-v-harrison-personal-injury-serious-injury-threshold Mon, 18 May 2026 20:00:00 GMT In a single personal injury case arising from a car accident in Westchester County, Judge Robert S. Ondrovic made two separate legal errors — denying the plaintiff's motion to amend his complaint to add a defendant, and granting summary judgment on the ground that the plaintiff had not sustained a s