Block v. Kumar

CourtDistrict Court, E.D. California
DecidedApril 22, 2024
Docket1:22-cv-01048
StatusUnknown

This text of Block v. Kumar (Block v. Kumar) is published on Counsel Stack Legal Research, covering District Court, E.D. California primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Block v. Kumar, (E.D. Cal. 2024).

Opinion

1 2 3 4 5 6 7 8 UNITED STATES DISTRICT COURT 9 FOR THE EASTERN DISTRICT OF CALIFORNIA 10 11 HENDRIK BLOCK, Case No. 1:22-cv-01048-KES-BAM 12 Plaintiff, ORDER GRANTING PLAINTIFF’S MOTION FOR LEAVE TO FILE SECOND 13 v. AMENDED COMPLAINT 14 JIWAN KUMAR, individually and dba (Doc. 36) DIDIER’S LIQUOR, et al., 15 Defendants 16 17 Currently pending before the Court is Plaintiff Hendrik Block’s motion for leave to file a 18 second amended complaint. (Doc. 36.) Defendants Jiwan Kumar, individually and d/b/a Didier’s 19 Liquor, and Santosh Kumar (collectively, “Defendants”) opposed the motion, and Plaintiff 20 replied. (Docs. 39, 40.) The Court found the motion suitable for decision without oral argument, 21 pursuant to Local Rule 230(g). (Doc. 43.) Counsel for Defendants subsequently filed a notice of 22 clarification confirming that she represented both Defendants Jiwan Kumar, individually and 23 d/b/a Didier’s Liquor, and Santosh Kumar. (Doc. 44.) 24 Having considered the motion, opposition, reply, and record in this case, Plaintiff’s 25 motion for leave to file a Second Amended Complaint will be GRANTED pursuant to Federal 26 Rule of Civil Procedure 15(a)(2). 27 /// 28 /// 1 BACKGROUND 2 On August 19, 2022, Plaintiff filed this action under the Americans with Disabilities Act 3 of 1990 (“ADA”), California’s Unruh Civil Rights Act (California Civil Code § 51), and the 4 California Health and Safety Code, alleging violations at Didier’s Liquor Store located in Fresno, 5 California based upon a March 11, 2022 visit. (Doc. 1.) By the complaint, Plaintiff sought 6 damages, injunctive and declaratory relief, and attorneys’ fees and costs against Defendants Jiwan 7 Kumar and Santosh Kumar. (Id.) Defendants filed a motion to dismiss for lack of jurisdiction, 8 and that motion was fully briefed and remains pending. (Docs. 13, 16, 23, 24.) 9 On December 19, 2022, Plaintiff amended his complaint as a matter of course. (Doc. 20.) 10 In the First Amended Complaint, Plaintiff included allegations related to a December 9, 2022 11 visit to Didier’s Liquor store in addition to the barriers encountered during a March 11, 2022 12 visit. (Id.) On January 16, 2023, Defendants filed a further motion to dismiss for lack of 13 jurisdiction as to Plaintiff’s amended complaint. (Doc. 25.) This motion was then fully briefed 14 and remains pending. (Docs. 25, 27, 28.) 15 The Court has not held a Scheduling Conference or issued a scheduling conference order 16 in light of the pending motions to dismiss. On February 15, 2024, Plaintiff filed the instant 17 motion for leave to file a Second Amended Complaint. (Doc. 36.) According to the motion, 18 Plaintiff seeks to amend the complaint to reflect the current property and business owners so that 19 he may seek injunctive relief from them. (Doc. 36-1 at 2.) In conjunction with the motion, 20 Plaintiff submitted a redline of the proposed Second Amended Complaint. (See Doc. 36-3 at 1- 21 16, Ex. A to Amended Declaration of Tanya E. Moore.) Defendants oppose the motion, arguing 22 that Plaintiff has not met the good cause standard of Federal Rule of Civil Procedure 15 or the 23 due diligence, good faith, and lack of dilatory actions standard under Federal Rule of Civil 24 Procedure 16. (Doc. 39.) Defendants further contend that permitting amendment of the 25 complaint would force Defendants to file a fourth motion to dismiss and create pressure for 26 Defendants to settle when there are no ADA barriers and Plaintiff lacks subject matter jurisdiction 27 as to some of the barriers alleged. (Id. at 4.) 28 1 DISCUSSION 2 Plaintiff’s motion to amend, filed prior to a scheduling order deadline for amendment, is 3 considered under the Federal Rule of Civil Procedure 15 standard for amendment to the 4 pleadings. See Johnson v. Mammoth Recreations, Inc., 975 F.2d 604, 608 (9th Cir. 1992) 5 (holding that motion to amend filed after pretrial scheduling order deadline must satisfy the 6 requirements of Federal Rule of Civil Procedure 16). Rule 15(a) provides that a court “should 7 freely give leave [to amend] when justice so requires.” Fed. R. Civ. P. 15(a)(2). The United 8 States Supreme Court has stated:

9 [i]n the absence of any apparent or declared reason—such as undue delay, bad faith or dilatory motive on the part of the movant, repeated failure to cure deficiencies 10 by amendments previously allowed, undue prejudice to the opposing party by virtue of allowance of the amendment, futility of amendment, etc. —the leave sought 11 should, as the rules require, be “freely given.” 12 Foman v. Davis, 371 U.S. 178, 182 (1962). The intent of the rule is to “facilitate decision on the 13 merits, rather than on the pleadings or technicalities.” Chudacoff v. Univ. Med. Center of S. Nev., 14 649 F.3d 1143, 1152 (9th Cir. 2011). Consequently, the “policy of favoring amendments to 15 pleadings should be applied with ‘extreme liberality.’” United States v. Webb, 655 F.2d 977, 979 16 (9th Cir. 1981). 17 “When considering whether to grant leave to amend, a district court should consider 18 several factors including undue delay, the movant’s bad faith or dilatory motive, repeated failure 19 to cure deficiencies by amendments previously allowed, undue prejudice to the opposing party, 20 and futility.” Brown v. Stored Value Cards, Inc., 953 F.3d 567, 574 (9th Cir. 2020) (citing 21 Foman, 371 U.S. at 182); Johnson v. Buckley, 356 F.3d 1067, 1077 (9th Cir. 2004). These factors 22 are not of equal weight as prejudice to the opposing party has long been held to be the most 23 critical factor in determining whether to grant leave to amend. Eminence Capital, LLC v. Aspeon, 24 Inc., 316 F.3d 1048, 1052 (9th Cir. 2003) (“As this circuit and others have held, it is the 25 consideration of prejudice to the opposing party that carries the greatest weight”); Jackson v. 26 Bank of Hawaii, 902 F.2d 1385, 1387 (9th Cir. 1990) (“Prejudice to the opposing party is the 27 most important factor.”). Absent prejudice, or a strong showing of any of the remaining factors, a 28 presumption exists under Rule 15(a) in favor of granting leave to amend. Eminence Capital, 316 1 F.3d at 1052. The Court now turns to the relevant factors. 2 Undue Delay 3 Defendants argue that Plaintiff should not be allowed to amend his complaint because the 4 amendment is inexcusably delayed. (Doc. 39 at 3.) In evaluating undue delay, the Court 5 considers “whether the moving party knew or should have known the facts and theories raised by 6 the amendment in the original pleading.” Jackson, 902 F.2d at 1388. In addition, the Court 7 examines whether “permitting an amendment would . . . produce an undue delay in the litigation.” 8 Id. at 1387. 9 Here, Plaintiff seeks to add a new business owner/operator and update the status of the 10 current Defendants as trustees based upon changes in ownership that occurred in 2023. (Doc. 36- 11 1 at 3-4; Doc.

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Bluebook (online)
Block v. Kumar, Counsel Stack Legal Research, https://law.counselstack.com/opinion/block-v-kumar-caed-2024.