Collingham v. Northfield Hospital and Clinics

Background

The plaintiffs are former employees of Northfield Hospital and Clinics. In August 2021, Northfield adopted a policy requiring employees to be fully vaccinated against COVID-19 by October 1, 2021. The policy allowed medical and religious exemption requests. Each plaintiff requested one or both types of exemption, but Northfield denied each request. The plaintiffs then refused vaccination as required by the policy, and they either resigned or Northfield terminated their employment.

The plaintiffs’ Second Amended Complaint asserted claims for religious discrimination and failure to accommodate under Title VII of the Civil Rights Act of 1964; disability discrimination and failure to accommodate under the Americans with Disabilities Act; disability discrimination and failure to accommodate under the Minnesota Human Rights Act; deprivation of rights under 42 U.S.C. § 1983; breach of contract; and failure to pay wages under Minnesota law. The parties later stipulated to dismissal of the § 1983 claim, leaving Northfield as the sole remaining defendant. The court also noted that six original plaintiffs had resolved their claims through settlement, but those plaintiffs had not yet been dismissed because the parties had not filed the required stipulation.

The scheduling order set November 30, 2022, as the deadline for further amendments to the pleadings. The plaintiffs filed their motion for leave to amend on January 2, 2024, seeking to add a seventh claim against Northfield under the Minnesota Human Rights Act for religious discrimination and failure to accommodate.

Legal standard

Because the motion came after the scheduling-order deadline, the court first applied Federal Rule of Civil Procedure 16(b). That rule requires a party to show “good cause” before amending a pleading after the deadline. The main consideration is the moving party’s diligence in trying to meet the deadline. Examples of possible good cause include a change in the law, newly discovered facts, or another significant changed circumstance. Only after finding good cause would the court consider the more permissive amendment standard under Rule 15(a).

The parties’ arguments

The plaintiffs argued that two recent decisions from the District of Minnesota had clarified the law and that they moved to amend soon after learning about those decisions. They also argued that the proposed Minnesota Human Rights Act claim was virtually or exactly the same as their existing Title VII failure-to-accommodate claims, so the discovery already conducted would address it and Northfield would not be prejudiced.

Northfield argued that the plaintiffs had not established good cause under Rule 16(b) for seeking amendment more than a year after the deadline.

Court’s analysis and ruling

The court concluded that the plaintiffs had not shown good cause. First, it found that the two cited decisions did not change or develop the applicable law and did not bind the court. Instead, the proposed amendment reflected a changed assessment of the claim’s merits and a change in litigation strategy. The court held that this was not enough to establish good cause.

Second, the court found that the proposed amendment was not based on changed facts. By arguing that the new claim was essentially identical to their existing claims and would rely on the same discovery, the plaintiffs acknowledged that they had the necessary facts when they began the lawsuit and when they filed the Second Amended Complaint.

Finally, the plaintiffs did not explain why they were unable to bring the proposed claim before the scheduling-order deadline or describe steps they had taken to pursue it diligently. The court therefore concluded that they failed to show good cause for filing the motion after the deadline.

The court ordered that the Plaintiffs’ Motion for Leave to Amend, Document No. 105, is DENIED.