Jonathan Graham v. Stryker Corporation, et al.

Summary

The United States District Court for the Eastern District of California denied Stryker Employment Company, LLC’s motion to amend its answer in Jonathan Graham’s wage-and-hour class action. The court held that the motion was subject to Federal Rule of Civil Procedure 16 because it was filed after the scheduling-order deadline, and that Stryker had not shown the required diligence and good cause. The proposed amendments included offset and arbitration defenses and revisions to existing defenses.

Holdings

1. Once the deadline for amending pleadings in a scheduling order has passed, Rule 16 governs the requested amendment, and the moving party must first show good cause before the court considers whether amendment is proper under Rule 15.
2. Stryker did not establish good cause because it was not diligent in seeking to add the offset and arbitration defenses.

Questions Presented

1. Whether a motion to amend an answer filed after the scheduling-order deadline is governed by Federal Rule of Civil Procedure 16 rather than Rule 15.
2. Whether Stryker demonstrated the Rule 16(b)(4) good cause required to amend the scheduling order and add the proposed affirmative defenses.

Disposition

other