Target Corporation v. Seaman Corporation
- Wilhelmina Wright
- 0:18-cv-03305
- U.S. District Court · District of Minnesota
- 2
In Target v. Seaman, Judge Menendez granted Target permission to add related claims because doing so would not unfairly prejudice Seaman.
Target Corporation may file a supplemental complaint, and Seaman Corporation must respond after it is filed.
What happened
Target Corporation v. Seaman Corporation concerns Target’s request to add claims about events that occurred after its original complaint. Target asked to file a supplemental complaint under a federal rule allowing later events to be added to a case.
Seaman argued that the new claims involved different facts, documents, witnesses, and transactions, and that adding them would cause prejudice after the case had been pending for more than a year and a half. The court found the proposed claims closely related to the existing claims and noted that the discovery schedule gave Seaman time to investigate them.
Judge Menendez granted Target’s motion. The court also rejected Seaman’s argument that Target had not shown good cause for missing the earlier pleading deadline, finding that Target had acted diligently because it could not have observed the roofing-membrane problems before that deadline. Target was ordered to file the supplemental complaint within three business days, and Seaman was ordered to respond within fourteen days after that filing.
The detailed version
- Target Corporation v. Seaman Corporation · No. 0:18-cv-03305
- Wilhelmina Wright
- July 30, 2020
Background
The court considered Target Corporation’s motion for permission to file a supplemental complaint under Federal Rule of Civil Procedure 15(d). That rule permits a party, on fair terms, to add allegations about a transaction, occurrence, or event that happened after the pleading being supplemented. The court explained that supplementation should generally be allowed when it promotes a fair resolution of the case, does not cause undue prejudice or delay, and does not harm the parties’ rights.
Parties’ Arguments
Seaman Corporation opposed the motion. It argued that Target’s proposed additional claims involved different transactions, occurrences, facts, documents, and witnesses, and that adding them would be prejudicial because the case had already been pending for more than a year and a half.
Seaman also argued that Target had not shown good cause under Federal Rule of Civil Procedure 16(b)(4) for seeking to supplement its pleading after the deadline in the scheduling order. Target relied on a declaration from Michael Fenner, its Lead Technical Specialist for the Building Envelope Team—Property Management. Fenner stated that Target could not have observed issues with the FiberTite roofing membrane at its Hastings and Waconia stores until after the December 2019 deadline.
Court’s Analysis
The court found that the proposed supplemental claims were closely related to the claims in the operative complaint. It concluded that allowing the supplemental complaint would not unfairly prejudice Seaman, particularly because the discovery schedule had recently been extended through May 3, 2021. That extension would give Seaman an adequate opportunity to examine the basis for Target’s additional claims. The court also concluded that Target had exercised reasonable diligence and therefore had shown good cause for the delayed filing.
Ruling
Judge Katherine Menendez granted Target’s motion for leave to file a supplemental complaint. The court ordered Target to file the proposed supplemental complaint within three business days of the order and ordered Seaman to file a responsive pleading within fourteen days after Target’s filing. The order addressed permission to supplement the pleadings; it did not decide the underlying claims’ merits.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.