Hunt v. Sunrise Operations LLC

Background

Andrew Hunt sued Sunrise Operations LLC and later amended his complaint to add The Pasha Group (TPG) as a defendant. Hunt alleges that he was terminated from his position as Chief Engineer for an old steamship because the defendants refused to consider accommodating his religious beliefs against receiving the COVID-19 vaccine. He alleges that Sunrise Operations was his former employer and that TPG was a joint employer responsible for the policies and practices leading to his termination.

Hunt moved for leave to file a Second Amended Complaint adding MEBA as a defendant. The opinion describes MEBA as a union but does not spell out the name. Hunt said he received an Equal Employment Opportunity Commission right-to-sue letter regarding MEBA on March 21, 2024. He also said that he had met and conferred with TPG about the proposed amendment. The court had shortened the time for hearing the motion because Hunt’s period to sue MEBA was set to expire on June 19, 2024.

Arguments and legal standard

TPG opposed the motion, arguing that Hunt acted in bad faith by keeping TPG in the case while adding MEBA and that he had delayed seeking the amendment. Under Federal Rule of Civil Procedure 15(a)(2), courts should freely allow amendments when justice requires. Relevant factors include undue delay, bad faith, futility, and prejudice to the opposing party, with prejudice treated as the most important factor.

Court’s analysis

The court found that Hunt sought to add a defendant, not new claims, after receiving a right-to-sue letter concerning that defendant. Discovery had not begun, only TPG had appeared, and the initial case-management conference had not yet occurred. The court therefore concluded that little of significance had happened in the case.

The court rejected TPG’s bad-faith argument. It also found no prejudice because adding MEBA would not prevent TPG from filing the dispositive motion it anticipated concerning the employment relationship between Hunt and TPG. The court agreed that Hunt should have acted more diligently after receiving the right-to-sue letter and warned that it would not look kindly on similar requests to shorten time in the future. Nevertheless, it did not find the delay sufficient to deny leave to amend.

Disposition

The court granted Hunt’s motion for leave to file the Second Amended Complaint. It ordered Hunt to file that complaint on the docket no later than June 11, 2024. The ruling addressed only whether Hunt could amend the pleading; it did not decide the merits of his allegations or claims.