Otis Bruce v. ITW Building Components Group, Inc.

Summary

The United States District Court for the Northern District of New York addresses defendant’s Rule 12(b)(6) motion and plaintiff’s cross-motion to file a second amended complaint in a products-liability action arising from a workplace injury involving a truss fabrication system. The court applies Rules 16 and 15, finds good cause and no futility, declines to consider disputed extraneous materials at the pleading stage, denies the motion to dismiss, and permits limited additional discovery concerning the defective component and whether defendant designed or manufactured it.

Holdings

1. A successive Rule 12(b)(6) motion was not procedurally improper under the circumstances, particularly because plaintiff sought leave to file a new operative pleading and the court needed to assess that proposed pleading's sufficiency.
2. The court would not consider plaintiff's expert report and other materials submitted outside the pleadings, and it would not convert the Rule 12(b)(6) motion into a motion for summary judgment.
3. Plaintiff demonstrated good cause under Rule 16(b)(4) to amend the complaint after the scheduling deadline.
4. The proposed second amended complaint was not futile because it plausibly alleged that a product or component of the truss-fabrication system was defectively designed or manufactured and that the defect was the actual and proximate cause of plaintiff's injury.

Questions Presented

1. Whether a second Rule 12(b)(6) motion was procedurally appropriate after plaintiff filed an amended complaint and cross-moved to amend again.
2. Whether the court could evaluate defendant's motion to dismiss against the allegations in the proposed second amended complaint.
3. Whether plaintiff demonstrated good cause under Federal Rule of Civil Procedure 16(b)(4) to amend after the scheduling deadline.
4. Whether the proposed second amended complaint was futile under Federal Rule of Civil Procedure 15(a)(2), including whether it plausibly alleged defective design or manufacture and actual and proximate causation.
5. Whether the court should consider materials outside the pleadings or convert the cross-motions into motions for summary judgment.

Disposition

other