FurnitureDealer.net, Inc. v. Amazon.com, Inc.

Background

FurnitureDealer.net objected to a magistrate judge’s November 7, 2019 order granting Briggs and Morgan, P.A.’s motion to withdraw as FurnitureDealer’s counsel. Briggs sought withdrawal after a conflict of interest arose in connection with a prospective merger with Taft Stettinius & Hollister, LLP, which the opinion says led to a breakdown in the attorney-client relationship. The magistrate judge found that Briggs had notified FurnitureDealer and shown good cause to withdraw because of a current conflict of interest.

FurnitureDealer also objected to the time allowed to obtain new counsel. It argued that Briggs needed Amazon’s consent to continue representing FurnitureDealer and that, if Amazon did not consent, the merged Briggs/Taft firm could no longer represent Amazon in any matter. FurnitureDealer separately requested a hearing on its objections.

Court’s Analysis

The district court reviewed the magistrate judge’s order under the deferential standard for nondispositive pretrial matters. Under that standard, the court could reverse only if the order was clearly erroneous or contrary to law.

The court found no error in allowing Briggs to withdraw. It relied on the magistrate judge’s finding that Briggs had given notice and shown good cause based on a current conflict of interest, which satisfied the applicable District of Minnesota local rule. The court also found that the authorities cited by FurnitureDealer concerned different situations, including a law firm opposing a former client in another matter or representing two clients directly adverse to each other in the same matter. The court stated that the merged Briggs/Taft firm did not represent Amazon in this matter and was not attempting to litigate another matter against FurnitureDealer.

The court likewise found no error in the timeline for obtaining new counsel. Although it found no error in that timeline, it granted FurnitureDealer a brief stay consistent with the magistrate judge’s ruling. The court denied FurnitureDealer’s request for a hearing because one was unnecessary.

Disposition

Judge John R. Tunheim overruled FurnitureDealer’s objection concerning the timeline, overruled its objection to the withdrawal order, and affirmed the magistrate judge’s November 7, 2019 order consistent with the district court’s ruling. The court stayed all discovery and deadlines from January 21, 2020, until the magistrate judge entered an amended pretrial scheduling order. Discovery was to recommence no later than February 28, 2020, unless the parties agreed otherwise.