Neher v. Coach Leasing, Inc.

Background

Plaintiff Hayley Neher moved to amend her complaint to add Megabus Northeast, LLC as a defendant. She said that discovery showed Megabus was the lessee of the bus that allegedly struck her. She also said she received a lease agreement showing that fact on or about August 4, 2020. Defendants Bernardo Fernandez and Coach Leasing, Inc. did not oppose the motion.

Legal standard

Federal Rule of Civil Procedure 15 generally directs courts to freely allow amendments to pleadings when justice requires. Rule 21 governs adding parties, and the court stated that the required showing under Rule 21 is the same as under Rule 15. Leave to amend may be denied for reasons such as futility, bad faith, unreasonable delay, or unfair prejudice to the opposing party. The party opposing amendment bears the burden of showing those grounds.

Court’s reasoning

The court found that the non-opposing defendants did not meet that burden. The court also found no futility, bad faith, or undue delay because Neher learned that Megabus was the bus’s lessee and conferred with the defendants the next day. The court further found that adding Megabus would not unfairly burden the defendants with significant additional costs or delays.

Disposition

Judge Lorna G. Schofield ordered that Neher’s motion to amend her complaint is GRANTED. The court directed Neher to file a non-redlined copy of the proposed amended complaint by September 17, 2020, and directed the Clerk of Court to close docket entry No. 13. The order addressed only whether Neher could add Megabus as a defendant; it did not decide the merits of her claims.