Miller v. Hamlett
- George Daniels
- 1:19-cv-11097-GBD-SDA
- U.S. District Court · Southern District of New York
- 3
In Miller v. Hamlett, Judge Daniels denied Miller’s motion to amend his complaint and closed the case.
David Eric Miller’s effort to amend his complaint was denied, and the case was closed; the defendants were not required to respond to the proposed amended claims in this order.
What happened
In Miller v. Hamlett, David Eric Miller alleged that the defendants possessed artwork belonging to his deceased father’s estate. Miller sued Brad Hamlett, The Wrangler Gallery, several trusts, an estate, and a John/Jane Doe defendant.
After discovery ended, the defendants sought judgment on the pleadings. The court previously adopted a recommendation granting that motion while allowing Miller to seek permission to amend if he could show a good reason for waiting. Miller later argued that the defendants had not produced his father’s will and that settlement discussions caused the delay.
The court rejected those explanations, overruled Miller’s objections, adopted Magistrate Judge Aaron’s recommendation, and denied the motion to amend. Judge George B. Daniels also directed the Clerk to close the motion and the case.
The detailed version
- Miller v. Hamlett · No. 1:19-cv-11097-GBD-SDA
- George Daniels
- Oct. 11, 2022
Background
David Eric Miller sued Brad Hamlett, The Wrangler Gallery, the Jan Ruyan Miller Trust, the Solomon Family Trust, the Estate of Sandra L. Solomon, and a John/Jane Doe defendant. He brought the action as administrator of, and as a distributee of, his deceased father David Humphreys Miller’s estate. Miller alleged that the defendants possessed artwork that belonged to the estate.
Prior proceedings
After discovery closed, the defendants moved for judgment on the pleadings under Federal Rule of Civil Procedure 12(c). Magistrate Judge Stewart D. Aaron recommended granting that motion but allowing Miller to file a formal motion to amend if he could show good cause—meaning a legally sufficient reason—for seeking amendment after the scheduling deadline. The district court adopted that recommendation and referred any amendment motion back to Magistrate Judge Aaron.
Motion to amend
Miller moved to amend his complaint on June 24, 2022. He attributed his delay to the defendants’ alleged refusal to produce his father’s last will and testament and to ongoing settlement negotiations. Magistrate Judge Aaron recommended denying the motion because Miller had not shown good cause under Rule 16(b). The recommendation noted that Miller had recognized by spring 2021 that the defendants did not possess the will, yet waited several months and until after the defendants filed their Rule 12(c) motion before seeking amendment. It also concluded that settlement negotiations did not excuse compliance with the scheduling deadlines.
The opinion further stated that the proposed amendments would be futile because the proposed claims were time-barred. It explained that Miller alleged his father died in 1992 and that the estate’s artwork passed to his stepmother at that time, while Miller did not bring this action until 2019. The opinion also stated that the proposed challenge to the probate of his father’s trust was untimely because that proceeding occurred in 2006 and California law provided a 120-day period to contest the trust.
Ruling
The district court found Magistrate Judge Aaron’s findings well-reasoned and found no clear error. It overruled Miller’s objections, adopted the recommendation, and denied Miller’s motion for leave to amend his complaint. Judge George B. Daniels directed the Clerk of Court to close the motion and the case.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.