Lopez v. Apple, Inc.
- Jeffrey White
- 4:19-cv-04577
- U.S. District Court · Northern District of California
- 2
In Lopez v. Apple, Judge White denied plaintiffs’ request to amend their class-action complaint and granted requests to seal.
The ruling affected the plaintiffs, who could not modify the scheduling deadline or file the proposed third amended complaint, and Apple, whose requests to file materials under seal were granted.
What happened
In Lopez v. Apple, Inc., the plaintiffs asked to change the scheduling order and file a third amended class-action complaint adding a plaintiff who owned a HomePod.
The court found that the plaintiffs had not shown the required diligence for extending the amendment deadline by nearly two years. It also found undue delay, some prejudice to Apple from additional discovery, and repeated failure to correct alleged complaint deficiencies through earlier amendments.
Judge Jeffrey White denied the motion for leave to modify the scheduling order and file the third amended complaint. The court granted the requests to file materials under seal.
The detailed version
- Lopez v. Apple, Inc. · No. 4:19-cv-04577
- Jeffrey White
- May 1, 2024
Background
The plaintiffs moved to modify the November 2, 2021 scheduling order and sought permission to file a third amended class-action complaint. The scheduling order set January 24, 2022, as the deadline for amending the pleadings. The proposed amendment would have added a plaintiff who owned a HomePod, one of the devices the plaintiffs contended was at issue in the case.
Rule 16 Analysis
Because the plaintiffs sought to extend the amendment deadline by nearly two years, the court applied Federal Rule of Civil Procedure 16. The court considered whether the plaintiffs had been diligent in helping establish the scheduling order, whether their failure to meet the deadline resulted from matters that could not reasonably have been anticipated, and whether they acted diligently once they could not meet the deadline.
The plaintiffs argued that they acted diligently because they moved to amend based on facts learned during discovery that were not known or knowable before the amendment deadline. The court rejected that explanation as false. It noted that, as early as February 10, 2021, the court had expressly found that none of the named plaintiffs owned a HomePod, and that the plaintiffs were in a position to know what types of devices they owned. The court therefore found that the plaintiffs failed to show diligence in seeking to amend the scheduling order.
Rule 15 Analysis
Although the court said it was unnecessary to separately review the motion under Federal Rule of Civil Procedure 15(a), it found that the plaintiffs also failed to satisfy that rule. The court identified undue delay, some prejudice to Apple from requiring additional discovery about the proposed new plaintiff, and repeated failure to cure alleged complaint deficiencies through prior amendments.
Disposition
The court denied the plaintiffs’ motion for leave to modify the scheduling order and leave to file a third amended class-action complaint. It granted the requests to file materials under seal, identified as docket entries 258 and 262.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.