Herrera v. County of San Benito

Summary

The United States District Court for the Northern District of California grants Rosario Herrera’s motion for leave to file a fourth amended complaint against the County of San Benito. The court finds good cause under Federal Rule of Civil Procedure 16(b) and concludes that amendment is appropriate under Rule 15(a), rejecting arguments of undue delay, bad faith, prejudice, and futility. The proposed amendment adds claims concerning failure to protect inmates, inadequate and reckless training, and alleged violations of the ADA and Rehabilitation Act.

Holdings

1. Plaintiff established good cause under Rule 16(b) because she acted diligently after learning facts supporting the proposed amendments through late discovery.
2. Leave to amend was warranted because Defendant did not establish undue prejudice or a strong showing of the other Foman factors, and Rule 15(a)'s policy favors liberal amendment.
3. The proposed claims were not shown to be futile because the court could not conclude from the face of the proposed complaint that no set of facts could support a valid claim; challenges concerning the merits and conflicting evidence were better addressed on a motion to dismiss or summary judgment.

Questions Presented

1. Whether Plaintiff showed good cause under Federal Rule of Civil Procedure 16(b) to modify the scheduling order and seek amendment after the deadline.
2. Whether leave to amend should be granted under Federal Rule of Civil Procedure 15(a) despite the timing of the motion, prior amendments, pending summary judgment, and Defendant's asserted prejudice.
3. Whether the proposed ADA and Rehabilitation Act claim was futile on the face of the proposed pleading.

Disposition

other