Rodney Tyger, et al v. Precision Drilling Corp., et al.

CourtDistrict Court, M.D. Pennsylvania
DecidedDecember 17, 2025
Docket4:11-cv-01913
StatusUnknown

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Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE MIDDLE DISTRICT OF PENNSYLVANIA

RODNEY TYGER, et al, No. 4:11-CV-01913

Plaintiffs. (Chief Judge Brann)

v.

PRECISION DRILLING CORP., et al.,

Defendants.

MEMORANDUM OPINION

DECEMBER 17, 2025 Earlier this year, the Court lifted its stay in this matter following the United States Court of Appeals for the Third Circuit’s second remand of a decision granting Defendants’ motion for summary judgment and the denial of Defendants’ petition for a writ of certiorari from the Third Circuit’s decision.1 Now pending before the Court is Plaintiffs’ motion to amend the complaint to add one additional count under Pennsylvania law. After reviewing the briefs and holding an oral argument, I will grant the motion. I. BACKGROUND Only a brief recitation of the facts and procedural history is necessary for resolution of this motion. This case was initiated more than 14 years ago, on October 17, 2011.2 Throughout the litigation, Plaintiffs have pursued recovery against Defendants on a single count for violating the Fair Labor Standards Act (“FLSA”)

by failing to pay overtime compensation.3 The sole factual theory is that Precision and its subsidiaries did not compensate their employees for time spent “donning and doffing” personal protective equipment (“PPE”) at work sites, or for time spent

walking between certain job site locations. Plaintiffs’ suit is being litigated as an FLSA Collective Action. The Court granted Defendants’ first motion for summary judgment as to liability in December 2019.4 The Third Circuit reversed and remanded,5 and the

parties filed renewed cross-motions for summary judgment on liability on March 1, 2021.6 Briefing on those motions completed on May 1, 2021.7 The Court granted Defendants’ renewed motion for summary judgment on March 25, 2022.8 The Third

Circuit again reversed and remanded on August 16, 2023.9 The Court did not immediately act after receiving the Third Circuit’s mandate to permit Defendants time to petition the Supreme Court of United States for a writ of certiorari.10 After the Supreme Court denied the petition, Plaintiffs advised the Court that they would

2 Doc. 1 (Compl.). 3 Doc. 8 (Am. Compl.) ¶¶ 45-52. 4 Doc. 365 (Mem. Op. & Order). 5 Doc. 382 (USCA Judgment). 6 Docs. 391, 392 (Mots.). 7 Docs. 406, 407 (Reply Briefs). 8 Doc. 409 (Mem. Op.). 9 Doc. 414 (Second USCA Judgment). 10 Docs. 418 (Letter), 419 (Sch. Order). file the instant motion to add a single count asserting claims for recovery for the same work done in Pennsylvania under Pennsylvania law, and did so shortly

thereafter.11 II. LAW First, there is some dispute over whether the Plaintiffs must satisfy Rule

16(b)(4)’s “good cause” standard for altering a scheduling order before the liberal amendment standard of Rule 15(a) controls.12 None of the scheduling orders in this case set a deadline for amending the complaint. Courts in this circuit are divided regarding the application of the Rule 16(b)(4) standard where the scheduling order

did not set a deadline for amendments.13 My practice has been not to apply Rule 16 where the scheduling order does not set a deadline.14 Even if Rule 16 should apply,

11 Docs. 421 (Status Report), 422 (Mot. to Amend). 12 See Premier Comp. Sols., LLC v. UPMC, 970 F.3d 316, 319 (3d Cir. 2020) (holding that “[W]hen a party moves to amend or add a party after the deadline in a district court’s scheduling order has passed, the ‘good cause’ standard of Rule 16(b)(4) of the Federal Rules of Civil Procedure applies. A party must meet this standard before a district court considers whether the party also meets Rule 15(a)’s more liberal standard.”). 13 Compare Smith v. Honeywell Int’l, Inc., No. 10-CV-3345, 2014 WL 301031, at *5 (D.N.J. Jan. 27, 2014) (“Where a scheduling order sets no amendment deadline, courts have looked to when discovery closes to determine whether the motion to amend is untimely under Rule 16. . . . Rule 16(b) applies to a motion to amend even when there is no scheduling order deadline, if ‘any possibility to amend the pleadings would expire when discovery closed.’” (internal citations omitted)) with Wagner v. Pat Salmon & Sons, Inc., No. 19-CV-1010, 2021 WL 229639, at *1 (M.D. Pa. Jan. 22, 2021) (Brann, J.) (“The case management order did ‘not include a deadline for filing amendments’ and therefore, Rule 16 is inapplicable to this motion to amend. Accordingly, the Court will apply Rule 15 to the instant motion.” (internal citation omitted)). 14 Wagner, 2021 WL 229639, at *1. Defendants cite my prior decisions applying Rule 16, but in both cases the scheduling order set a deadline for amendments. Miller v. O’Brien Constr., Inc., No. 19-CV-1611, 2021 WL 510072, at *1 (M.D. Pa. Feb. 11, 2021) (noting that “the Court set the deadline for filing amended pleadings on August 30, 2020”); Bolus v. Carnicella, No. 15- however, Plaintiffs have met the “good cause” standard for the reasons explained in the Rule 15 “undue delay” analysis below, so there is no need to conduct an

independent analysis under Rule 16. At the present stage of the litigation, Plaintiffs may amend their complaint “only with the opposing party’s written consent or the court’s leave.”15 Rule 15 directs the court to “freely give leave [to amend] when justice so requires.”16 This

command embodies a “liberal standard for motions to amend.”17 Accordingly, the presumption is in favor of permitting amendment, and the non-moving party generally bears the burden of demonstrating why leave should be denied.18

Moreover, the grounds for denying amendment are limited. The nonmovant must show “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 allowance of the amendment, [or] futility of

CV-1062, 2020 WL 6203056, at *3 (M.D. Pa. Oct. 22, 2020) (“Neither party contests that amended pleadings were due by October 29, 2018.”). 15 Fed. R. Civ. P. 15(a)(2). 16 Id. 17 Spartan Concrete Prods., LLC v. Argos USVI, Corp., 929 F.3d 107, 115 (3d Cir. 2019) 18 Kern v. Phoenixville Hosp., LLC, 342 F.R.D. 324, 327 (E.D. Pa. 2022); Heraeus Med. GmbH v. Esschem, Inc., 321 F.R.D. 215, 217 (E.D. Pa. 2017); see Brooks v. State Coll. Area Sch. Dist., No. 22-CV-1335, 2023 WL 8359953, at *2 (M.D. Pa. Dec. 1, 2023) (Brann, J.). amendment” in order to justify denial.19 Whether to grant or deny a motion to amend lies within the district court’s discretion.20

III. ANALYSIS Defendants assert three justifications for denying leave to amend here. First, they contend that Plaintiffs unduly delayed in requesting leave to amend. Second,

although not clearly delineated in the briefing, they offer a somewhat convoluted argument that amendment would be futile. Finally, they complain that permitting the amendment will prejudice them by requiring additional discovery and postponing resolution of this already protracted case.

A. Undue Delay “The mere passage of time does not require that a motion to amend a complaint be denied on grounds of delay. In fact, delay alone is an insufficient ground to deny leave to amend.”21 To deny amendment, the movant’s delay must be

“undue,” meaning that it “is ‘protracted and unjustified’—it ‘can place a burden on the court or counterparty’ or show ‘a lack of diligence sufficient to justify a discretionary denial of leave.’ A district court may exercise its discretion to deny

19 Foman v. Davis, 371 U.S. 178

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