Guzman v. Americare, Inc.

Summary

The Appellate Division, First Department, affirmed the denial of defendants’ motion to amend their answer to add constitutional defenses challenging the definition of the certified class. The court held that the proposed defense was plainly meritless because it contravened the court’s prior class-certification determination and that permitting the amendment would prejudice the plaintiff.

Holdings

1. Leave to amend was properly denied because the proposed defense was patently devoid of merit and contravened the court's prior determination that plaintiff was entitled to class certification.
2. Leave to amend was also properly denied because permitting defendants to challenge class certification again at that late stage would prejudice plaintiff.

Questions Presented

1. Whether defendants should have been granted leave to amend their answer to add an affirmative defense asserting that the certified class violated their due process rights.
2. Whether the proposed constitutional defense was sufficiently meritorious to warrant amendment despite the prior class-certification determination and the late stage of the litigation.

Disposition

affirmed