Upperline Healthcare, PC v. Jaclyn “Carli” Hoover

Summary

The United States District Court for the Middle District of Tennessee considers Upperline Healthcare, PC’s motion for leave to file a first amended complaint in a dispute concerning restrictive covenants in an employment agreement with Jaclyn “Carli” Hoover. Upperline sought to add claims and defendants based on alleged breaches, disparagement, and tortious interference. The court applies Federal Rules of Civil Procedure 16(b), 15(a), and 15(d), and denies the motion because Upperline did not establish good cause or sufficient diligence and the amendment would prejudice Hoover.

Holdings

1. When a motion to amend is filed after the scheduling-order deadline, the movant must first show good cause under Rule 16(b) before the court considers whether amendment is proper under Rule 15(a).
2. Upperline failed to establish good cause for extending the deadline to amend because it did not act diligently and waited too long to seek amendment despite possessing information concerning several proposed claims before the deadline or well before filing its motion.
3. The requested amendment would substantially prejudice Hoover because it would require her to rework her summary-judgment briefing, reopen discovery, and potentially litigate personal-jurisdiction motions concerning the proposed new defendants.

Questions Presented

1. Whether Upperline established good cause under Federal Rule of Civil Procedure 16(b)(4) to modify the scheduling-order deadline for amending pleadings.
2. Whether the proposed amendment would prejudice Hoover.
3. Whether the court needed to determine the Rule 15(a)(2) propriety or potential futility of the proposed amendment after Upperline failed to satisfy Rule 16(b).

Disposition

other