Muchiarone v. Board of Education

District Court, N.D. Ohio·Decided September 16, 2025·No. 3:24-cv-01688·Unknown

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF OHIO WESTERN DIVISION

TAMARA MUCHIARONE, CASE NO. 3:24 CV 1688

Plaintiff,

v. JUDGE JAMES R. KNEPP II

BOARD OF EDUCATION OF THE TOLEDO CITY SCHOOL DISTRICT, et al., MEMORANDUM OPINION AND Defendants. ORDER

INTRODUCTION Currently pending before the Court is Defendant Carnel Smith’s Renewed Motion for Leave to File Counterclaim Instanter Based on New Evidence. (Doc. 26). Plaintiff Tamara Muchiarone opposes and requests sanctions. (Doc. 28). Smith did not reply and the time in which to do so has expired. Jurisdiction in this matter is proper under 28 U.S.C. §§ 1331 and 1367. For the reasons set forth below, the Court denies Smith’s Motion. BACKGROUND As this Court set forth in its previous Order addressing Smith’s first motion for leave, Plaintiff filed the instant case on September 30, 2024, naming as Defendants the Board of Education of the Toledo City School District and Carnel Smith. (Doc. 1). Plaintiff, a teacher, alleges Smith, the principal at her school, sexually harassed her. See id. She brings claims for sexual harassment, hostile work environment, sex discrimination, and retaliation under Title VII and Ohio state law. See id. At a November 19, 2024, case management conference, the Court set December 10, 2024, as the deadline to amend pleadings. (Doc. 8, at 2). This date was jointly proposed by the parties in their Report of Parties’ Planning Meeting. (Doc. 7, at 2). On April 4, 2025, Smith filed his first motion to amend to add a counterclaim for abuse of process. (Doc. 14). Following briefing, this Court denied that motion on July 21, 2025. (Doc.

23). Therein, the Court noted that it was inclined to find a lack of good cause to modify the scheduling order under Rule 16, but ultimately ruled that the proposed amendment would be futile, as the parties focused their arguments on the Rule 15 factors. See id. at 5-11. The Court held that the proposed counterclaim was futile because Smith did “not allege any ‘further act’ Plaintiff has undertaken ‘in the use of process not proper in the regular conduct of the proceeding’” as required for an abuse of process claim. (Doc. 23, at 10) (citing Clermont Envt’l Reclamation Co. v. Hancock, 16 Ohio App. 3d 9, 11 (1984)). STANDARD OF REVIEW Amendment to add a counterclaim is governed by Rule 15 of the Federal Rules of Civil

Procedure. See Fed. R. Civ. P. 13 advisory committee’s note to 2009 amendment (“Rule 13(f) is deleted as largely redundant and potentially misleading. An amendment to add a counterclaim will be governed by Rule 15.”); Fed. R. Civ. P. 15 advisory committee’s note to 2009 amendment (“Abrogation of Rule 13(f) establishes Rule 15 as the sole rule governing amendment of a pleading to add a counterclaim.”). After a party’s right to amend its pleading as a matter of course expires, a party may amend only with the opposing party’s written consent or leave of court. Fed. R. Civ. P. 15(a). Under Rule 15(a)(2), courts “should freely give leave when justice so requires.” The appropriate factors to consider in determining whether to permit an amendment include: “the delay in filing, the lack of notice to the opposing party, bad faith by the moving party, repeated failure to cure deficiencies by previous amendments, undue prejudice to the opposing party, and futility of amendment.” Perkins v. Am. Elec. Power Fuel Supply, Inc., 246 F.3d 593, 605 (6th Cir. 2001). A district court enjoys “considerable discretion” in determining

whether leave should be granted. Leisure Caviar, LLC v. U.S. Fish & Wildlife Serv., 616 F.3d 612, 615 (6th Cir. 2010). In addition to the requirements of Rule 15, Rule 16 provides that a scheduling order establishing deadlines for matters such as amendments to pleadings “may be modified only for good cause and with the judge’s consent.” Fed. R. Civ. P. 16(b)(4). “Thus, when seeking to amend after the deadline in the scheduling order, the movant must satisfy not only the relatively liberal requirements of Rule 15 but also the more exacting ‘good cause’ standard of Rule 16.” Snyder v. Erie Ins. Exch., 2023 WL 12047213, at *1 (W.D. Tenn.). Unlike Rule 15, Rule 16 also requires diligence by the party seeking amendment. Smith v. Holston Med. Grp., P.C., 595 F.

App’x 474, 478 (6th Cir. 2014) (“‘The primary measure of Rule 16’s “good cause” standard is the moving party’s diligence in attempting to meet the case management order’s requirements,’ though courts may also consider prejudice to the nonmoving party.”) (quoting Inge v. Rock Fin. Corp., 281 F.3d 613, 625 (6th Cir. 2002)). Once a scheduling order’s deadline passes, therefore, a party must first show good cause under Rule 16(b) for the failure to seek leave to amend prior to the scheduling order’s deadline before a Court will consider whether amendment is proper under Rule 15(a). Leary v. Daeschner, 349 F.3d 888, 909 (6th Cir. 2003). A determination of the potential prejudice to the nonmoving party is also required in deciding whether to allow amendment. Id. Good Cause Under Rule 16 As the Court stated in its previous Order, it is Smith’s burden, as the party seeking amendment after the scheduling order’s deadline, to “show good cause under Rule 16(b) for failure earlier to seek leave to amend before a court will consider whether amendment is proper under Rule 15(a).” Leary, 349 F.3d at 909; Korn v. Paul Revere Life Ins. Co., 382 F. App’x 443,

449 (6th Cir. 2010) (holding a party who fails to seek leave to amend a scheduling order deadline must demonstrate good cause for the failure to timely move); OM Shiv Hosp., L.L.C. v. Northfield Ins. Co., 2025 WL 1762288, at *2 (S.D. Ohio) (“The party seeking to amend the scheduling order bears the burden of demonstrating good cause.”). Parties “can demonstrate ‘good cause’ for their failure to comply with the original schedule . . . by showing that despite their diligence they could not meet the original deadline.” Leary, 349 F.3d at 907; see also Marcilis v. Twp. of Redford, 693 F.3d 589, 597 (6th Cir. 2012) (“A court asked to modify a scheduling order for good cause ‘may do so only if [a deadline] cannot reasonably be met despite the diligence of the party seeking the extension.’”) (quoting

Leary, 349 F.3d at 906); Inge, 281 F.3d at 625 (“The primary measure of Rule 16’s ‘good cause’ standard is the moving party’s diligence in attempting to meet the case management order’s requirements”). DISCUSSION Smith, now for the second time, moves for leave to file a counterclaim against Plaintiff for the Ohio state law claim of abuse of process. (Doc. 26). He asserts that “[n]ew evidence has been discovered” since the filing of his first motion that demonstrates the “further act” necessary to assert an abuse of process claim. Id. at 2. The new evidence Smith cites is from Plaintiff’s May 2025 deposition. Id. at 3.

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