Gary M. Bloom v. William James Campbell III

Summary

The United States District Court for the District of Massachusetts denied Gary M. Bloom’s motion for leave to amend his complaint to add six defendants and new claims. The court found undue delay and prejudice because the motion was filed after the amendment deadline, after fact discovery had closed, and after Bloom had filed motions for declaratory judgment and summary judgment.

Holdings

1. A party seeking amendment after a scheduling-order deadline must demonstrate good cause, with the court focusing primarily on the party's diligence rather than merely on prejudice to the opponent.
2. Leave to amend may be denied when a party's protracted delay would substantially delay the litigation, require reopening discovery, and impose significant additional costs and procedural burdens on the opposing party.

Questions Presented

1. Whether Bloom showed good cause under Federal Rule of Civil Procedure 16(b) to modify the scheduling order and seek amendment after the amendment deadline.
2. Whether leave to amend should be denied under Rule 15(a)(2) because the proposed amendment would cause undue delay and prejudice.

Disposition

other