Garcia v. Harley-Davidson Motor Company, Inc.

Background

Ronald Garcia moved for permission to file an amended complaint. The proposed amendment would remove claims that the court had previously dismissed and reduce the scope of the class Garcia sought to represent by excluding residents of certain states.

Harley-Davidson Motor Company Group, LLC opposed the motion only on the ground that the amendment could disrupt its motions to stay—meaning requests to pause—other cases filed later in the states whose residents Garcia would exclude. The hearing scheduled for April 24, 2020, was vacated because the court found the matter suitable for decision without oral argument.

Court’s Analysis

Because the deadline for amending as a matter of right had passed and Harley-Davidson did not consent, Garcia needed the court’s permission. Under Rule 15 of the Federal Rules of Civil Procedure, courts generally should freely allow amendments before trial when justice requires, and the court described that policy as being applied with “extreme liberality.”

The court noted that Harley-Davidson cited no case holding that a plaintiff must continue pursuing class claims for people the plaintiff no longer wishes to represent before a class has been certified or a motion for class certification has been filed.

Ruling

The court granted Garcia’s motion for leave to amend. It ordered Garcia to file his second amended complaint as a separate docket entry no later than April 22, 2020, and stated that Harley-Davidson must respond in due course. The court expressly left for the courts handling the other cases the question whether those cases should be stayed under the first-to-file rule and expressed no opinion on that issue.

This was a procedural ruling about amending the pleadings; the order did not decide the underlying claims or whether a class should ultimately be certified.