Carson v. Seaspan Corporation

Background

Steven Carson brought negligence and products-liability claims in Alameda County Superior Court against CMA CGM (America) LLC, Seaspan Corporation, and Seaspan Ship Management Ltd. He alleged that he was injured while loading containers onto a vessel owned by defendants. Seaspan Corporation and Seaspan Ship Management Ltd. removed the case to federal court based on diversity jurisdiction. The court also allowed Homeport Insurance Company, which paid Carson workers’ compensation benefits after the incident, to intervene.

Carson moved under Federal Rule of Civil Procedure 15(a)(2) to amend his complaint and add Cargotec Oyj, MacGregor Germany GmbH, Cargotec Holding, Inc., and Cargotec Crane & Electrical Services, Inc. as defendants. Carson relied on documents produced by the Seaspan entities indicating that a MacGregor company manufactured the container stacking cones involved in the accident. The current defendants did not oppose the motion.

Court’s Analysis

Rule 15(a)(2) provides that courts should freely allow amendments when justice requires, but leave may be denied for prejudice, bad faith, undue delay, or futility. The court found no material prejudice because fact discovery would remain open for more than three months, and defendants had not identified discovery that would need to be repeated. The court also found no evidence of bad faith or undue delay. Carson received relevant documents on July 29 and September 3, 2019, investigated the entities involved, sought agreement to the amendment, and filed his motion before the amendment deadline. Finally, the court found nothing suggesting that the proposed amendment would be futile.

Disposition

The court granted Carson’s unopposed motion to amend the complaint to add the four proposed defendants. It ordered Carson to file the proposed amended complaint within three business days.