The following excerpt is from Yu v. City of N.Y., 18-3838 (2nd Cir. 2020):
We also vacate in part the district court's dismissal with prejudice for failure to state a cause of action under federal law or the NYSHRL. Typically, a pro se plaintiff must be "grant[ed] leave to amend at least once when a liberal reading of the complaint gives any indication that a valid claim might be stated." Cuoco v. Moritsugu, 222 F.3d 99, 112 (2d Cir. 2000) (internal quotation marks and citation omitted). However, leave to amend need not be granted where amendment would be futile because the problems with the complaint's claims are substantive and not the result of inartful pleading. Id. The district court based its dismissal with prejudice on futility grounds.
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