Santos v. Fidelity National Title Insurance Company

CourtDistrict Court, S.D. California
DecidedMay 9, 2025
Docket3:24-cv-02069
StatusUnknown

This text of Santos v. Fidelity National Title Insurance Company (Santos v. Fidelity National Title Insurance Company) is published on Counsel Stack Legal Research, covering District Court, S.D. California primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Santos v. Fidelity National Title Insurance Company, (S.D. Cal. 2025).

Opinion

1 2 3 4 5 6 7 8 UNITED STATES DISTRICT COURT 9 SOUTHERN DISTRICT OF CALIFORNIA 10 11 J. ELIZABETH SANTOS and GLORIA Case No.: 24cv2069-GPC(MSB) P. SANTOS, Trustees of the GHS Living 12 Trust, ORDER GRANTING PLAINITFFS’ 13 MOTION FOR LEAVE TO FILE A Plaintiffs, SECOND AMENDED COMPLAINT 14 v. 15 [Dkt. No. 21.] FIDELITY NATIONAL TITLE 16 INSURANCE COMPANY, as successor to American Title Insurance Company, 17 Defendant. 18

19 Plaintiffs filed a motion for leave to file a second amended complaint. (Dkt. No. 20 21.) Defendant filed an opposition and Plaintiffs replied. (Dkt. Nos. 26, 27.) Based on 21 the reasoning below, the Court GRANTS Plaintiff’s motion for leave to file a second 22 amended complaint. 23 Background 24 On November 4, 2024, Plaintiff J. Elizabeth Santos and Gloria P. Santos, as 25 Trustee of the GHS Living Trust (“Plaintiffs or “Insured”) filed a complaint against 26 Defendant Fidelity National Title Insurance Company (“Defendant” or “Fidelity”) 27 seeking declaratory relief and alleges claims for breach of contract, bad faith, and in the 28 1 alternative, contract reformation. (Dkt. No. 1, Compl.) In response to the Court’s order 2 to show cause why the case should not be dismissed for lack of subject matter 3 jurisdiction, Plaintiffs responded and the Court dissolved the order to show cause. (Dkt. 4 Nos. 4, 5, 6.) On November 22, 2024, Plaintiffs filed an amended complaint to properly 5 allege subject matter jurisdiction. (Dkt. No. 7.) 6 Defendant filed an answer on January 2, 2025. (Dkt. No. 8.) On March 3, 2025, 7 Defendant filed a motion for judgment on the pleadings. (Dkt. No. 12.) Then, on April 8 9, 2025, Plaintiffs filed the instant motion for leave to file a second amended complaint. 9 (Dkt. No. 21.) In the meantime, on April 11, 2025, Plaintiffs filed a response to 10 Defendant’s motion for judgment on the pleadings and a motion for partial summary 11 judgment. (Dkt. Nos. 22, 23.) On April 28, 2025, Defendant filed an opposition to the 12 motion for leave to file a second amended complaint. (Dkt. No. 26.) A reply was filed 13 by Plaintiffs on May 6, 2025. (Dkt. No. 27.) 14 Discussion 15 Under Federal Rule of Civil Procedure (“Rule”) 15, courts “should freely give leave 16 [to amend] when justice so requires.” Fed. R. Civ. P. 15(a)(2); see also Foman v. Davis, 17 371 U.S. 178, 182 (1962) (“Rule 15(a) declares that leave to amend ‘shall be freely given 18 when justice so requires’; this mandate is to be heeded.”). Granting leave to amend rests 19 in the sound discretion of the trial court. Int’l Ass’n of Machinists & Aerospace Workers 20 v. Republic Airlines, 761 F.2d 1386, 1390 (9th Cir. 1985). 21 “Five factors are taken into account to assess the propriety of a motion for leave to 22 amend: bad faith, undue delay, prejudice to the opposing party, futility of amendment, and 23 whether the plaintiff has previously amended the complaint.” Johnson v. Buckley, 356 24 F.3d 1067, 1077 (9th Cir. 2004); see also Foman, 371 U.S. at 182 (Foman factors). These 25 factors do not carry equal weight; the possibility of delay alone, for instance, cannot justify 26 denial of leave to amend, but when combined with a showing of prejudice, bad faith, or 27 futility of amendment, leave to amend will likely be denied. DCD Programs, Ltd., 833 28 F.2d at 186; Bowles v. Reade, 198 F.3d 752, 757-58 (9th Cir. 1999). The single most 1 important factor is whether prejudice would result to the non-movant as a consequence of 2 the amendment. Eminence Cap., LLC v. Aspeon, Inc., 316 F.3d 1048, 1052 (9th Cir. 2003); 3 William Inglis & Sons Baking Co. v. ITT Continental Baking Co., Inc., 668 F.2d 1014, 4 1053 n.68 (9th Cir. 1981). “Absent prejudice, or a strong showing of any of the remaining 5 . . . factors, there exists a presumption under Rule 15(a) in favor of granting leave to 6 amend.” Eminence Cap. LLC, 316 F.3d at 1052 (emphasis in original). The burden of 7 demonstrating prejudice falls on the party opposing leave to amend. DCD Programs, Ltd., 8 833 F.2d at 187. When determining whether to grant leave to amend, courts “must remain 9 guided by ‘the underlying purpose of Rule 15 . . . to facilitate decision on the merits, rather 10 than on the pleadings or technicalities.’” Lopez v. Smith, 203 F.3d 1122, 1127 (9th Cir. 11 2000) (en banc) (quoting Noll v. Carlson, 809 F.2d 1446 (9th Cir. 1987)). 12 Plaintiffs contend that the Foman factors support their motion. They argue there has 13 been no undue delay as they filed the motion within days of discovering the factual error 14 while preparing their opposition to the motion for judgment on the pleadings. (Dkt. No. 15 21-2 at 4.) They also assert that the amendment is not due to bad faith or dilatory motive 16 but to provide factual accuracy of the pleadings and even reached out to defense counsel 17 to avoid any delay in the case. (Id. at 5.) They claim this is their first request to cure the 18 pleading deficiency noting that the prior amendment was filed in response to the Court’s 19 order to show cause. (Id.) They further maintain that the proposed amendment will not 20 prejudice Defendant because the case is in its infancy, and finally, the proposed amendment 21 is not futile because any claims as to the merits of the proposed pleading can be raised after 22 the pleadings have been finalized. In opposition, Defendant contends that the proposed 23 amendments (1) are futile; and (2) will unfairly prejudice it. (Dkt. No. 26.) 24 A. Futility 25 “[A proposed] amendment is futile when no set of facts can be proved under the 26 amendment to the pleadings that would constitute a valid and sufficient claim or defense.” 27 Missouri ex rel. Koster v. Harris, 847 F.3d 646, 656 (9th Cir. 2017) (citation and quotation 28 marks omitted). “Denial of leave to amend on this ground is rare. Ordinarily, courts will 1 defer consideration of [futility] challenges . . . until after leave to amend is granted and the 2 amended pleading is filed.” Netbula, LLC v. Distinct Corp., 212 F.R.D. 534, 539 (N.D. 3 Cal. 2003); Green Valley Corp. v. Caldo Oil Co., No. 09cv4028-LHK, 2011 WL 1465883, 4 at *6 (N.D. Cal. Apr. 18, 2011) (noting “the general preference against denying a motion 5 for leave to amend based on futility”); see also Clarke v. Upton, 703 F. Supp. 2d 1037, 6 1043 (E.D. Cal. 2010) (“However, denial [of a motion to amend] on this ground is rare and 7 courts generally defer considerations of challenges to the merits of a proposed amended 8 pleading until after leave to amend is granted and the amended pleading is filed.”). As the 9 Ninth Circuit explained, “[i]t would be undesirable to resolve important legal questions on 10 the basis of allegations which are incomplete” and “[i]t has been said that the sufficiency 11 of an amended pleading ordinarily will not be considered on motion for leave to amend.” 12 Breier v. N. Cal.

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Related

Foman v. Davis
371 U.S. 178 (Supreme Court, 1962)
United States v. Daniel James Fowlie
24 F.3d 1059 (Ninth Circuit, 1994)
Clarke v. Upton
703 F. Supp. 2d 1037 (E.D. California, 2010)
State of Missouri v. Kamala Harris
847 F.3d 646 (Ninth Circuit, 2016)
Bowles v. Reade
198 F.3d 752 (Ninth Circuit, 1999)
Lopez v. Smith
203 F.3d 1122 (Ninth Circuit, 2000)
Netbula, LLC v. Distinct Corp.
212 F.R.D. 534 (N.D. California, 2003)
Noll v. Carlson
809 F.2d 1446 (Ninth Circuit, 1987)

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Santos v. Fidelity National Title Insurance Company, Counsel Stack Legal Research, https://law.counselstack.com/opinion/santos-v-fidelity-national-title-insurance-company-casd-2025.