Brief Fact Summary. Plaintiff, the administratrix of Janette Christopher, who died from pneumonia stemming from her hospitalization for lead poisoning, moved to amend her complaint to include new Defendants under the original injury action.
Synopsis of Rule of Law. A court, under Federal Rule of Civil Procedure 15, can deny a plaintiff’s motion for a leave to amend if new defendants would be prejudiced by the delay.
Issue. The issue is whether the lower court abused their discretion in denying Plaintiff’s leave to amend her complaint.
Held. The court held that it was not an abuse of discretion and that the leave should have been denied. The court cited Massachusetts Rule of Civil Procedure (which parallels Federal Rule 15) as support for a judge to deny a leave for amendment when there is a good reason to deny it. The prejudice to the new Defendants would be great since it is six years after the fact and the most important witness and co-Defendant, Duffy, passed away.
A motion to amend should be allowed unless some good reason appears for denying it.View Full Point of Law