Crescent Mine, LLC v. Bunker Hill Mining Corporation; Placer Mining Corporation (d/b/a New Bunker Hill Mining Co.)

Summary

The United States District Court for the District of Idaho ruled on motions to amend pleadings and motions to seal in consolidated litigation involving CERCLA response costs and related state-law claims arising from mining activities. The court granted Bunker Hill Mining Corporation's motion to add a statute-of-limitations defense, denied Crescent Mine's request to add plaintiffs and seek punitive damages, and granted three motions to seal. The punitive-damages request was denied without prejudice.

Holdings

1. Bunker Hill established good cause under Rule 16(b) because the expert report presented a potentially new theory of ongoing water movement and Bunker Hill moved promptly after that theory arose. The amendment was also permissible under Rule 15(a), so the motion to amend the answers was granted.
2. Crescent failed to establish good cause under Rule 16(b) because it did not explain its lack of diligence in waiting more than two years after the amendment deadline and six months after discovery closed. The request to add Crescent Silver, LLC and Syringa Exploration, Inc. as plaintiffs was denied with prejudice.
3. Crescent's motion to add a punitive-damages claim was denied without prejudice because the present record did not permit the court to determine as a matter of law that a punitive-damages instruction was appropriate.
4. The three motions to seal were granted because the identified materials fell within the parties' stipulated protective order and primarily contained financial information or trade secrets, providing compelling reasons to overcome the presumption of public access.

Questions Presented

1. Whether Bunker Hill Mining Corporation established good cause under Federal Rule of Civil Procedure 16(b) and satisfied Rule 15(a) to amend its answers to add a statute-of-limitations affirmative defense.
2. Whether Crescent Mine established good cause under Rule 16(b) to amend its complaint to add Crescent Silver, LLC and Syringa Exploration, Inc. as plaintiffs after the amendment and discovery deadlines.
3. Whether Crescent Mine demonstrated under Idaho Code section 6-1604(2) a reasonable probability of proving facts sufficient to support a punitive-damages award.
4. Whether the materials identified in the three motions to seal qualified for sealing under the compelling-reasons standard governing judicial records associated with dispositive motions.

Disposition

other