Pichowicz v. Atlantic Richfield

CourtDistrict Court, D. New Hampshire
DecidedFebruary 8, 1996
DocketCV-92-388-M
StatusPublished

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

Bluebook
Pichowicz v. Atlantic Richfield, (D.N.H. 1996).

Opinion

Pichowicz v. Atlantic Richfield CV-92-388-M 02/08/96 UNITED STATES DISTRICT COURT FOR THE DISTRICT OF NEW HAMPSHIRE

Nicholas and Joan Pichowicz, Plaintiffs, and NH VT Health Service, Intervenor-Plaintiff,

v. Civil No. 92-388-M

Atlantic Richfield, Defendant/Counter-Claimant, and Stephen Bronstein; James Fokas; and Herbert Miller, Defendants/ Cross-Claimants/Counter-Defendants.

O R D E R

Plaintiffs, Nicholas and Joan Pichowicz, have sued

defendants. Pearl Hoyt, et al., seeking compensation for damage

to their property caused by defendants' alleged release of

contaminants. In an order dated January 4, 1995, the magistrate

judge denied defendants' motion for leave to amend their answer

to assert the affirmative defense of contractual release from

liability.

The proposed affirmative defense is based on a "General

Release" (the "Release") that plaintiffs allegedly gave

defendants in 1988 in settlement of a prior lawsuit. Defendants

obtained a copy of the Release from plaintiffs' counsel through

informal discovery in October 1995. Prior to that date,

defendants claim they did not specifically recall the existence

of the Release or its terms and could not locate their own copy of the Release. Nor, it appears, were defendants' counsel aware

of the Release before late 1995, not having represented

defendants in the earlier lawsuit or settlement.

Pursuant to Fed. R. Civ. P. 72, defendants now appeal the

magistrate judge's order and reguest this court to grant their

motion for leave to amend. For the reasons stated below, the

defendants' motion for leave to amend is granted.

I. STANDARD OF REVIEW

Federal Rule of Civil Procedure 72 governs objections to

non-dispositive orders issued by a magistrate judge: "The

district judge to whom the case is assigned shall consider such

objections and shall modify or set aside any portion of the

magistrate judge's order found to be clearly erroneous or

contrary to law." Fed. R. Civ. P. 72(a) (emphasis added).1 A

magistrate judge's factual finding is considered clearly

erroneous when it is contrary to the "clear weight of the

evidence or when the court has a definite and firm conviction

1 Defendants argue that this court should employ the less deferential de novo standard that Fed. R. Civ. P. 72(b) prescribes for review of a magistrate judge's report and recommendation on a dispositive pretrial matter. Because, in this case, the magistrate judge's order must be reversed even under the more deferential standard of review applicable to non- dispositive matters, the court need not decide whether defendants' motion to amend to assert a potentially dispositive affirmative defense constitutes a dispositive pretrial matter under Fed. R. Civ. P. 72(b).

2 that a mistake has been committed." Havden v. Gravstone, No.

C93-112-JD, slip op. at 2 (D.N.H. Aug. 30, 1995) (DiClerico,

C.J.) (quotation omitted).

II. DISCUSSION

Federal Rule of Civil Procedure 15 governs leave to amend

pleadings: "[A] party may amend the party's pleading only by

leave of court or by written consent of the adverse party; and

leave shall be freely given when justice so requires." Fed. R.

Civ. P . 15(a).

In 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 by amendments previously allowed, undue prejudice to the opposing party by virtue of the allowance of the amendment, futility of the amendment, etc. — the leave sought should, as the rules require, be "freely given."

Foman v. Davis, 371 U.S. 178, 182 (19 62); see also Executive

Leasing Corp. v. Banco Popular, 48 F.3d 66, 71 (1st Cir. 1995).

Plaintiffs do not claim, nor did the magistrate judge find,

bad faith, dilatory motive, or repeated failure to cure

deficiencies on the part of defendants. In addition, the

magistrate judge correctly concluded that the proposed amendment

is not futile. The Release is facially broad, and, absent clear

and convincing evidence that it does not express the parties'

3 intentions — evidence lacking here — it would normally be given

full effect under New Hampshire law. Maltais v. National Grange

Mut. Ins. C o ., 118 N.H. 318, 320 (1978). Rather, the magistrate

judge based his denial of defendants' motion to amend on a

finding that defendants' undue delay in moving to amend their

answer would prejudice plaintiffs if the motion for leave to

amend were granted.

Delay, standing alone, is usually an insufficient basis on

which to deny leave to amend. Greenberg v. Mvnczvwor, 667 F.

Supp. 901, 905 (D.N.H. 1987) (citing Carter v. Supermarkets Gen'1

Corp., 684 F.2d 187, 192 (1st Cir. 1982)). However, "unseemly

delay, in combination with other factors, may warrant denial of a

suggested amendment." Quaker State Oil Ref, v. Garritv Oil Co.,

884 F.2d 1510, 1517 (1st Cir. 1989) (emphasis added).

Specifically, the "district court must consider prejudice to the

opposing party." Greenberg, 667 F. Supp. at 905. Prejudice is

present when the amendment would reguire the non-movant to expend

significant additional resources to conduct discovery and prepare

for trial. Block v. First Blood Assoc., 988 F.2d 344, 350 (2d

Cir. 1993), or deprive the non-movant of the opportunity to

present facts or evidence. Bryn Mawr Hosp. v. Coatesville Elec.

Supply C o ., 776 F. Supp. 181, 186 (E.D. Pa. 1991) (citing Foman,

371 U.S. at 182.) .

4 The magistrate judge based his conclusion that defendants'

tardy amendment would prejudice plaintiffs on two findings: (1)

that plaintiffs had already expended considerable resources in

preparing this case; and (2) that "discovery closes in less than

sixty days." (Order at 6.) The first finding, while certainly

unassailable, does not speak to the type of prejudice

contemplated by Rule 15, and the second finding is incorrect due

to an oversight.

The parties have undoubtedly spent much time and money

litigating this case. But the real guestion is whether

permitting defendants to add an affirmative defense at this point

will prejudice plaintiffs by reguiring them to expend significant

additional resources. Implicit in the magistrate judge's ruling

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Related

Foman v. Davis
371 U.S. 178 (Supreme Court, 1962)
Maltais v. National Grange Mutual Insurance
386 A.2d 1264 (Supreme Court of New Hampshire, 1978)
Greenberg v. Mynczywor
667 F. Supp. 901 (D. New Hampshire, 1987)
Bryn Mawr Hospital v. Coatesville Electric Supply Co.
776 F. Supp. 181 (E.D. Pennsylvania, 1991)
Block v. First Blood Associates
988 F.2d 344 (Second Circuit, 1993)

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