Third Circuit Rules Attempts To Amend Pleadings in Federal Court After Deadline Must Be Supported by Good Cause

In the case of Premier Comp Solutions v. UPMC, No. 19-1838 (3d Cir. Aug. 12, 2020) (Op. by Hardiman, J.), the court addressed the discretion of federal district trial court judges to manage their dockets, particularly with respect to allowing amendments to Complaints or the joinder of additional parties after the expiration of deadlines set in the trial court's case management order.

According to the Opinion, Plaintiff in this matter moved to amend its Complaint to add a party well after the expiration of the deadline for amendments to pleadings that the district court had set in a Scheduling Order. 

In its motion, the Plaintiffs cited the liberal standard set forth in Rule 15 of the Federal Rules of Civil Procedure, which is entitled "Amended and Supplemental Pleadings." The district court denied the motion under the rationale that, because the deadline had passed, Federal Rule of Civil Procedure 16(b)(4) required the Plaintiff to show good cause. Federal Rule of Civil Procedure addresses, in part, rules pertaining to "Scheduling" issues.

The Third Circuit Court of Appeals affirmed the decision of the district court under the reasoning that Rule 16(b)(4) applies to requested amendments once a Scheduling Order deadline for the same has passed. As such, under this standard, after the deadline set by the district court’s Scheduling Order has expired, a party is required to show good cause to allow for the amendment 

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Source: “Court: Post-Deadline, Parties Required to Show ‘Good Cause’ to Amend Complaints or Add Parties,” by P.J. D’Annunzio of the Pennsylvania Law Weekly (August 13, 2020).