eLearning, LLC v. Scott Vickers and ExpiTrans, Inc.

Summary

The United States District Court for the District of Utah denied eLearning, LLC’s motion for leave to file a second amended complaint. The court held that Plaintiff failed to show good cause under Federal Rule of Civil Procedure 16(b)(4) for missing the scheduling-order amendment deadline and, alternatively, that the amendment was unduly delayed and would prejudice Defendants under Rule 15(a)(2).

Holdings

1. Plaintiff failed to establish good cause because it did not demonstrate that the scheduling deadline could not be met despite diligent efforts. Plaintiff did not identify the purportedly new discovery, state when it learned the information, or explain the delay before seeking amendment.
2. Even if Plaintiff had established good cause under Rule 16(b)(4), the court would deny leave under Rule 15(a)(2) because the motion was unduly delayed and lacked an adequate explanation for the delay.
3. Allowing Plaintiff to add six causes of action would unduly prejudice Defendants because it would likely require reopening discovery and extending other deadlines after Defendants had completed discovery and moved for summary judgment.

Questions Presented

1. Whether Plaintiff established good cause under Federal Rule of Civil Procedure 16(b)(4) to extend the expired deadline for moving to amend the complaint.
2. Whether, assuming good cause existed, Plaintiff satisfied Federal Rule of Civil Procedure 15(a)(2) for leave to file a second amended complaint.
3. Whether the proposed amendment would cause undue delay or undue prejudice to Defendants.

Disposition

other