Nathan P. Goldstein, as Executive Director, Massachusetts Laborers’ Benefit Funds v. Essential Demo, Inc.

Summary

The United States District Court for the District of Massachusetts denied Essential Demo, Inc.’s motion for leave to file a crossclaim against Rise Construction Management, Inc. The court applied Federal Rules of Civil Procedure 13(g), 15, and 16(b), concluding that Essential failed to show good cause because it knew the factual basis for the proposed crossclaim and offered no explanation for filing after the amendment deadline. The underlying dispute concerns allegedly unpaid employee-benefit contributions under ERISA and the LMRA.

Holdings

1. When a scheduling order has been entered and the deadline for amendments to pleadings has passed, a party seeking leave to add a crossclaim must satisfy Rule 16(b)'s more demanding good-cause standard before proceeding under Rule 15.
2. Essential failed to establish good cause because it was aware of the factual basis for the proposed crossclaim for a substantial period, could have asserted it before the deadline, and offered no excuse for its delay; therefore, leave to file the crossclaim was denied.

Questions Presented

1. Whether Essential Demo could obtain leave under Federal Rules of Civil Procedure 16(b) and 15 to file a crossclaim after the deadline for amendments to pleadings.
2. Whether Essential demonstrated good cause, particularly diligence, for modifying the scheduling order and allowing the proposed crossclaim.

Disposition

other