September McDowell and Robert Robinson v. City of Elizabeth, et al.

Summary

The United States District Court for the District of New Jersey denied Plaintiffs’ appeal from a magistrate judge’s order concerning leave to amend their complaint. The court held that Plaintiffs failed to demonstrate the diligence and good cause required under Federal Rule of Civil Procedure 16(b)(4) to amend after the scheduling-order deadline. The court affirmed the magistrate judge’s May 13, 2025 Opinion and Order and concluded that consideration under the more liberal Rule 15(a) standard was unnecessary.

Holdings

1. Plaintiffs failed to show the diligence required to establish good cause under Rule 16(b)(4), and the magistrate judge's determination was neither clearly erroneous nor contrary to law.
2. The magistrate judge properly declined to conduct a Rule 15(a) analysis because satisfaction of Rule 16(b)(4) is a threshold requirement for an untimely motion to amend.

Questions Presented

1. Whether the magistrate judge clearly erred or acted contrary to law in finding that Plaintiffs failed to establish good cause and due diligence under Federal Rule of Civil Procedure 16(b)(4) for seeking amendment after the scheduling-order deadline.
2. Whether the magistrate judge was required to analyze the proposed amendment under the more liberal standard of Federal Rule of Civil Procedure 15(a) despite Plaintiffs' failure to satisfy Rule 16(b)(4).

Disposition

affirmed