Butler v. 3M Company

CourtDistrict Court, S.D. Ohio
DecidedDecember 9, 2024
Docket2:24-cv-01587
StatusUnknown

This text of Butler v. 3M Company (Butler v. 3M Company) is published on Counsel Stack Legal Research, covering District Court, S.D. Ohio primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Butler v. 3M Company, (S.D. Ohio 2024).

Opinion

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF OHIO EASTERN DIVISION

BRENDA BUTLER, : Plaintiff, Case No. 2:24-cv-01587

Chief Judge Sarah D. Morrison v. Magistrate Judge Kimberly A.

Jolson 3M COMPANY, et al., : Defendants.

OPINION AND ORDER This matter is before the Court on the motion to amend the complaint filed by Brenda Butler (ECF No. 46). Defendants 3M Company and Arizant Healthcare Inc. responded (ECF No. 51), and Ms. Butler filed a Reply (ECF No. 54). This matter is now ripe for consideration. For the reasons set forth below, the Motion is GRANTED in part and DENIED in part. I. BACKGROUND

This case is one of many product liability actions consolidated for coordinated pretrial proceedings as part of a multidistrict litigation (“MDL”) against 3M and its wholly owned subsidiary, Arizant Healthcare. (ECF No. 4, PAGEID # 12); In re Bair Hugger Forced Air Warming Devices Prods. Liab. Litig., MDL No. 15-2666 (D. Minn.). The MDL plaintiffs generally assert that they underwent orthopedic- implant surgeries and thereafter contracted joint infections; they allege the infections were caused by the use of the “Bair Hugger” system—a convective (or “forced-air”) patient-warming device manufactured and sold by 3M—during their surgeries. (ECF No. 51, PAGEID # 356); In re Bair Hugger, MDL No. 15-2666, ECF No. 1, at 2 (D. Minn. Dec. 11, 2015). In May 2016, the MDL plaintiffs “filed a Master Long Form Complaint and a

Master Short Form Complaint as administrative devices to set forth potential claims” that could be asserted against Defendants.1 In re Bair Hugger, MDL No. 15- 2666, ECF No. 46, at 1–3 (D. Minn. May 25, 2016). The MDL court authorized future plaintiffs to file their own version of the Short Form Complaint articulating in an abbreviated manner their individualized “injury, the dates, the home state, the plaintiff’s date of birth, the basic theories of liability, and the suggested jurisdiction for remand.” Id. Future plaintiffs were also given “the express right to

file and serve an Amended Complaint, upon the showing required by the relevant Federal Rules of Civil Procedure and any applicable court order, … which more fully sets forth the facts specific to their case, the causes of action and allegations … and theories of liability alleged.” Id. Ms. Butler directly filed her Short Form Complaint in the MDL on August 4, 2023. (ECF No. 1.) Therein, Ms. Butler states that she underwent surgery at

OhioHealth Berger Hospital in Circleville, Ohio, in September 2014 and that her doctors used the Bair Hugger system during her procedure. (Id., ¶ 7.) Ms. Butler

1 The MDL court established (1) July 29, 2016, as the deadline by which the MDL plaintiffs could amend the Master Complaints without leave of court; and (2) April 21, 2017, as the deadline by which the MDL plaintiffs could move to amend the Master Complaints to include punitive damages claims. In re Bair Hugger, MDL No. 15-2666, ECF No. 175 (“MDL Scheduling Order”), at 2 (D. Minn. Jan. 5, 2017); see also id., ECF No. 27, at 1 (D. Minn. Mar. 24, 2016). asserts that “[c]ontaminants introduced into [her] open surgical wound as a direct and proximate result of use of the Bair Hugger during the subject surgery” caused her to develop a joint infection that required “numerous procedures[,] …

intervention, management, and surgeries.” (Id., ¶¶ 8–9.) She alleges various claims under common law and Ohio and Minnesota consumer protection statutes. (Id., ¶ 12; id., PAGEID # 4.) Ms. Butler’s case was selected as an MDL bellwether action. In re Bair Hugger, MDL No. 15-2666, ECF No. 2386, at 5 (D. Minn. Dec. 28, 2023). In April 2024, the MDL court transferred 28 bellwether cases, including Ms. Butler’s action, to the district courts where they would have been filed absent the direct filing order

previously issued by the MDL court. (ECF No. 10, PAGEID # 36.) Accordingly, Ms. Butler’s case was transferred to this Court. (Id., PAGEID # 43.) Shortly thereafter, the parties submitted a Joint Rule 26(f) Report, in which Ms. Butler foreshadowed her intent to seek “leave to submit an Amended Complaint that will comply with Ohio law and avoid a likely FRCP 12(c) motion to dismiss.” (ECF No. 36, PAGEID # 218.) In response, Defendants argued that the deadline to

further amend complaints was set by the MDL court in the MDL Scheduling Order and had passed, such that Ms. Butler could not amend without showing good cause. (Id., PAGEID # 218–19.) By order of the Court, the parties subsequently filed a revised Rule 26(f) Report that reflected only their agreement that any motion to amend would be due on June 10, 2024. (ECF No. 38, PAGEID # 234.) The Court entered a scheduling order (“Ohio Scheduling Order”) memorializing the amendment deadline. (ECF No. 40, PAGEID # 243.) On June 7, 2024, Ms. Butler filed the instant Motion seeking to amend her

Complaint (ECF No. 46). She represents that her proposed Amended Complaint “maintains the same causes of action … against the same Defendants from the original complaint” and serves to “conform” the “purely administrative” Short Form Complaint to her own individualized circumstances. (Id., PAGEID # 280.) Defendants oppose Ms. Butler’s request, which they characterize as part of a “broader strategy to use the transferred bellwether cases to reopen and relitigate general discovery outside of the MDL court.” (ECF No. 51, PAGEID # 355.) They

contend that Ms. Butler should have more timely sought leave to amend and that her proposed amendments are futile. (Id., PAGEID # 360, 364.) II. STANDARD OF REVIEW

Pursuant to Federal Rule of Civil Procedure 15(a)(2), when a party seeks leave to file an amended pleading, “[t]he court should freely give leave when justice so requires.” This rule, which allows a liberal policy in favor of granting amendments, “reinforce[s] the principle that cases ‘should be tried on their merits rather than the technicalities of pleadings.’” Inge v. Rock Fin. Corp., 388 F.3d 930, 936 (6th Cir. 2004) (quoting Moore v. City of Paducah, 790 F.2d 557, 559 (6th Cir. 1986)). Thus, trial courts enjoy broad discretion in deciding motions for leave to amend. See Gen. Elec. Co. v. Sargent & Lundy, 916 F.2d 1119, 1130 (6th Cir. 1990). In exercising its discretion, a trial court may consider such factors as “undue delay, bad faith or dilatory motive on the part of a movant, repeated failures to cure deficiencies by amendments previously allowed, undue prejudice to the opposing party by virtue of allowance of the amendment, [and] futility of the amendment.”

Foman v. Davis, 371 U.S. 178, 182 (1962). However, if a party moves to amend after the deadline established in a scheduling order, she “must meet the higher threshold for modifying a scheduling order found in [Federal Rule of Civil Procedure] 16(b).” Shane v. Bunzl Distrib. USA, Inc., 275 F. App’x 535, 536 (6th Cir. 2008). The party must “show good cause under Rule 16(b) for the failure to seek leave to amend prior to the expiration of the deadline before [the court] will consider whether the amendment is proper under

Rule 15(a).” Hill v. Banks, 85 F. App’x 432, 433 (6th Cir. 2003).

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