IBEW Local 98 Pension Fund v. Best Buy Co., Inc.

Background

Lead Plaintiff objected to Magistrate Judge Franklin L. Noel’s July 11, 2018 order. That order denied Lead Plaintiff’s motion to file a second amended complaint under Federal Rules of Civil Procedure 16(b)(4) and 15(a).

Under Rule 16(b)(4), a party seeking to amend a pleading after the scheduling deadline must show good cause. Magistrate Judge Noel found that newly discovered facts, a change in circumstances, or a change in law did not justify Lead Plaintiff’s late motion. Under Rule 15(a)(2), the magistrate judge also found undue delay and prejudice to Defendants. The order further stated that the law-of-the-case doctrine—generally, the principle that a court should follow earlier rulings in the same case—supported denying the amendment because the proposed complaint sought to revive claims that had previously been dismissed.

Objection

Lead Plaintiff argued that the magistrate judge’s order was clearly erroneous or contrary to law. Lead Plaintiff asserted that the proposed complaint relied on newly discovered evidence produced after the amendment deadline, that good cause existed, that the law-of-the-case doctrine did not bar the amendment, and that prejudice had been suffered only by Lead Plaintiff and the proposed class.

The district court reviewed the objection under a highly deferential standard. It could modify or set aside the magistrate judge’s order only if the order was clearly mistaken or contrary to law.

Ruling

The court denied Lead Plaintiff’s objection and affirmed Magistrate Judge Noel’s July 11, 2018 order in all respects. Judge Donovan W. Frank concluded that Lead Plaintiff had not established that the magistrate judge’s decision was clearly erroneous or contrary to law. The court specifically agreed that Lead Plaintiff had no justification for delaying the amendment and that allowing it would prejudice Defendants.

The order therefore overruled Lead Plaintiff’s objection and affirmed the magistrate judge’s order denying permission to file a second amended complaint.