Stewart v. Shelby Tissue, Inc.

Brief Fact Summary.

Plaintiff filed a lawsuit against his previous employer. Plaintiff later filed a motion for leave to file supplemental claims after Defendant sent letters to his new employer that caused him to be fired.

Synopsis of Rule of Law.

Supplemental pleadings, governed by Rule 15(d), are granted unless there is a showing of undue delay, trial inconvenience, and prejudice to the parties.

Facts.

Dennis Stewart (Plaintiff) entered into an employment contract with Shelby Tissue, Inc. (Defendant), a subsidiary of General Electric Capital Corporation (Defendant). A year later, Plaintiff resigned, filed suit against Defendants, and began working for Kruger, Inc. Plaintiff was subsequently fired from this position, after Defendants sent Kruger a letter asserting that his employment with Kruger violated a noncompetition clause of his contract. Plaintiff amended his complaint to include claims of unlawful inducement of breach of contract and tortious interference with contractual relations. Plaintiff then filed a motion for leave to file these supplemental claims. The Defendants had not yet filed an answer in response to the original pleadings.

Issue.

Can Plaintiff file these additional claims, either as an amended complaint or supplemental complaint?

Held.

Yes, Plaintiff can file these additional claims as a supplemental complaint under Rule 15(d).

Discussion.

The Court determines that Rule 15(d) applies here because the Plaintiff’s new claims arose after the original complaint was filed. Additionally, the Court determines that the motion for leave to file the supplemental complaint should be granted because there was no showing of undue delay, trial inconvenience, or prejudice to the Defendants, given the timing and merits of the claims.