Court Reviews Standard of Review For Motion to Amend Complaint in Federal Court

In the case of Moravia Motorcycle, Inc. v. Allstate Ins. Co., No.2:21-cv-01274-PLD (W.D. Pa. Oct. 19, 2022 Dodge, Mag. J.), the court addressed a Plaintiff’s Motion for Leave to Amend Complaint and join an additional party which was opposed by the Defendant carrier in this breach of contract and bad faith claim. The court denied the Motion.

According to the Opinion, this case involved a claim by the Plaintiffs against the Defendant carrier in which they sought benefits under an insurance policy for damage to their motorhome.

The court noted that the Plaintiff was relying upon F.R.C.P. 15(a)(2) in seeking to amend their Complaint. Under that Rule, it is provided that, when a party moves to amend a pleading, “the court should freely give leave when justice so requires.”

However, the magistrate judge in this case noted that the Third Circuit Court of Appeals has held that a party seeking to amend after the deadline in a Case Management Order is required to meet the good cause standard of F.R.C.P. 16(b)(4), and not the more liberal standard of Rule 15(a)(2).

In reviewing the record before it, the court noted that there was evidence that the Plaintiff was aware of the possible need to join in another party before the deadline to amend actually expired. In the end, the court found that the Plaintiff had not met the good cause standard.

The court also went on to state that, even if the Plaintiff had met the good cause standard, because their motion sought to add a non-diverse party, the Plaintiffs would have been required to meet other factors in order to be allowed to amend to join a non-diverse party.

The court noted that some of the factors which may be considered by a court when faced with a Motion to Add a Non-Diverse Party would include the extent to which the purpose of the amendment is to defeat federal jurisdiction, whether the Plaintiff had been dilatory in requesting the amendment, whether the Plaintiff would be significantly injured if the amendment is not allowed, and other equitable factors. The court in this matter noted that it did not appear that these particular factors had yet been adopted in the Third Circuit but had been utilized in other federal circuits.

Nevertheless, after reviewing the factors as applied in this case, the court ruled that the factors weighed against allowing the joinder of the non-diverse Defendant in any event.

Anyone wishing to review a copy of this decision may click this LINK.

I send thanks to Attorney Joseph Hudock of the Pittsburgh office law firm of Summers, McDonnell, Hudock, Guthrie & Rauch, P.C. for bringing this case to my attention.

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 

Anyone wishing to review a copy of this decision may click this LINK.



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).