Peter Sayegh v. Automatic Data Processing Incorporated

CourtDistrict Court, D. Arizona
DecidedNovember 6, 2025
Docket2:24-cv-00277
StatusUnknown

This text of Peter Sayegh v. Automatic Data Processing Incorporated (Peter Sayegh v. Automatic Data Processing Incorporated) is published on Counsel Stack Legal Research, covering District Court, D. Arizona primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Peter Sayegh v. Automatic Data Processing Incorporated, (D. Ariz. 2025).

Opinion

1 WO 2 3 4 5 6 IN THE UNITED STATES DISTRICT COURT 7 FOR THE DISTRICT OF ARIZONA

9 Peter Sayegh, No. CV-24-00277-PHX-SMB

10 Plaintiff, ORDER

11 v.

12 Automatic Data Processing Incorporated,

13 Defendant. 14 15 Pending before the Court is Plaintiff Peter Sayegh’s Motion for Voluntary Dismissal 16 (Doc. 140). Defendant Automatic Data Processing, Inc. (“ADP”) does not oppose the 17 dismissal if the Court grants the dismissal with prejudice or, in the alternative, without 18 prejudice but with conditions (Doc. 148). Having reviewed the briefing and the relevant 19 case law, the Court grants Plaintiff’s Motion without prejudice. 20 I. BACKGROUND 21 In February 2025, Plaintiff’s counsel withdrew from this case. (Doc. 45.) Since 22 then, Plaintiff claims he has contacted over 130 attorneys and yet been unsuccessful in 23 securing new representation. (Doc. 148 at 3.) Plaintiff informs the Court that this litigation 24 has taken a “profound toll” on his “mental, emotional, and physical health.” (Doc. 140 at 1 25 n.1.) Therefore, Plaintiff seeks voluntary dismissal for two reasons. First, because he 26 “cannot ethically proceed” given his professional duty to “withdraw when his physical or 27 mental condition materially impairs his ability” to represent himself and “his ongoing 28 obligations to other clients.” (Id. at 2.) Second, “to protect Plaintiff’s health from the risk 1 of a severe mental or nervous breakdown that could result if he were forced to continue 2 litigating without modifications.” (Id. at 3.) 3 II. LEGAL STANDARD 4 Under Rule 41(a)(2), after an opposing party has served an answer or motion for 5 summary judgment, “an action may be dismissed at the plaintiff’s request only by court 6 order, on terms that the court considers proper.” “Unless the order states otherwise, a 7 dismissal under this paragraph (2) is without prejudice.” Id. “The purpose of the rule is to 8 permit a plaintiff to dismiss an action without prejudice so long as the defendant will not 9 be prejudiced, or unfairly affected by dismissal.” Stevedoring Servs. of Am. v. Armilla Int’l 10 B.V., 889 F.2d 919, 921 (9th Cir. 1989) (citation omitted). 11 III. DISCUSSION 12 The decision to grant or deny a motion pursuant to Rule 41(a)(2) is “within the 13 sound discretion of the trial court.” Phillips v. Ill. Cent. Gulf R.R., 874 F.2d 984, 986 (9th 14 Cir. 1989). A court typically grants a voluntary dismissal unless doing so would prejudice 15 the defendant. See Westlands Water Dist. v. United States, 100 F.3d 94, 96 (9th Cir. 1996). 16 If dismissal is granted, a court may condition the dismissal on appropriate terms and 17 conditions to protect the defendant’s interests. See Hamilton v. Firestone Tire & Rubber 18 Co., 679 F.2d 143, 146 (9th Cir. 1982). 19 A. Prejudice 20 “‘Legal prejudice’ is a term of art: it means ‘prejudice to some legal interest, some 21 legal claim, some legal argument.” Kamal v. Eden Creamery, LLC, 88 F.4th 1268, 1280 22 (9th Cir. 2023) (quoting Westlands, 100 F.3d at 97). Thus, a court evaluates if dismissal 23 would harm “the rights and defenses available to a defendant in future litigation.” 24 Westlands, 100 F.3d at 97. 25 Here, Defendant argues the Court should grant Plaintiff’s voluntary dismissal with 26 prejudice. See Williams v. Peralta Cmty. Coll. Dist., 227 F.R.D. 538, 539–40 (N.D. Cal. 27 2005) (noting that dismissal with prejudice may be appropriate where it would be 28 inequitable or prejudicial to a defendant to allow a plaintiff to refile an action). However, 1 in arguing whether the Court should dismiss with or without prejudice, Defendant cites 2 case law from district courts in this circuit that have adopted a three-factor-test employed 3 by the Eight Circuit. (Doc. 148 at 5–9.) That test is as follows: The following factors are relevant in determining whether the dismissal 4 should be with or without prejudice: “(1) the defendant’s effort and expense 5 involved in preparing for trial, (2) excessive delay and lack of diligence on the part of the plaintiff in prosecuting the action, [and] (3) insufficient 6 explanation of the need to take a dismissal.” 7 Burnette v. Godshall, 828 F. Supp. 1439, 1443–44 (N.D. Cal. 1993) (quoting Paulucci v. 8 City of Duluth, 826 F.2d 780, 783 (8th Cir. 1987)). Notably, “the Ninth Circuit has never 9 endorsed those bases in a published decision and has expressly ‘decline[d] to adopt the 10 Eight Circuits analysis in Paulucci.’” Dew Wealth Mgmt. LLC v. Wesley Leftwich, No. 11 CV-25-01416-PHX-DWL, 2025 WL 2958636, at *7 (D. Ariz. Oct. 20, 2025) (quoting 12 Westlands, 100 F.3d at 97). 13 More importantly, the Ninth Circuit appears to reject these factors wholesale. See 14 Westlands, 100 F.3d at 97 (“We have explicitly stated that the expense incurred in 15 defending against a lawsuit does not amount to legal prejudice.” (emphasis added)); 16 Kamal, 88 F.4th at 1282 (“Defendants argue that when deciding whether dismissal should 17 be with or without prejudice, the district court may consider other factors ‘not rising to the 18 level of legal prejudice,’ such as ‘the defendant’s effort and expense involved in preparing 19 for trial’ and ‘excessive delay and lack of diligence on the part of the plaintiff in prosecuting 20 the action,’ and may dismiss with prejudice if warranted by these considerations. But we 21 have already rejected similar arguments.” (emphasis added)). Such rejection tracks the 22 Ninth Circuit’s narrow interpretation of what amounts to legal prejudice: 23 Uncertainty because a dispute remains unresolved is not legal prejudice, and the threat of future litigation which causes uncertainty is insufficient to 24 establish plain legal prejudice. Additionally, the mere inconvenience of 25 defending another lawsuit does not constitute plain legal prejudice, and plain legal prejudice does not result merely because the defendant will be 26 inconvenienced by having to defend in another forum or where a plaintiff 27 would gain a tactical advantage by that dismissal. 28 Kamal, 88 F.4th at 1280 (citation modified). Accordingly, the Court will not endorse 1 Defendant’s three-factor-approach and will only evaluate whether granting Plaintiff’s 2 voluntary dismissal will prejudice “some legal interest, some legal claim, some legal 3 argument.” Westlands, 100 F.3d at 97. 4 Here, Defendant asks the Court to grant Plaintiff’s dismissal with prejudice because 5 “ADP has incurred significant effort and expense preparing for trial in this matter.” (Doc. 6 148 at 5.) The Court rejects this argument. “[E]xpense[s] incurred in defending a lawsuit 7 do[] not amount to legal prejudice.” Westlands, 100 F.3d at 97. 8 Next, Defendant argues that “allowing Plaintiff to voluntarily dismiss without 9 prejudice unless and until he obtains outside outside-counsel has the potential to create a 10 significant boon for Plaintiff to ADP’s detriment.” (Doc. 148 at 2.) Even if true, such a 11 windfall would not establish legal prejudice. “[P]lain legal prejudice does not 12 result . . . where a plaintiff would gain a tactical advantage by that dismissal.” Smith v. 13 Lenches, 263 F.3d 972, 976 (9th Cir. 2001).

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