Brief Fact Summary. Plaintiffs, M.K. et al., amended their complaints against Defendants, CIA director George Tenet et al., for violations pertaining to their employment at the CIA.
Synopsis of Rule of Law. The court has discretion in viewing on a case-by-case basis whether a complaint amendment is not unduly burdensome on the opposing party, and they will look at factors such as whether discovery has yet to take place.
However, because statute of limitations issues often depend on contested questions of fact, courts should hesitate to dismiss a complaint on statute of limitations grounds based solely on the face of the complaint.View Full Point of Law
Issue. The issue is whether Plaintiffs amended claim should be granted and whether Defendants may sever six Plaintiffs from the claim.
Held. The court held that there was not an undue burden and allowed the amended claim without allowing Defendants motion to sever. Discovery has yet to take place, and Defendants were unable to point to any specific Rule 8 violations (Rule 8 ensures that a claim is plainly stated to ensure that there is no burden on the party to respond to the complaint). The court also agreed with Plaintiffs’ Rule 20(a) transactional test that argued that the claims by each Plaintiff were logically related.
Discussion. The court noted that Plaintiffs were not repeatedly going back to the well to amend their complaints; rather, this was their first amendment and it occurred before discovery.