Strawhecker v. Laurel School District

100 F.R.D. 7, 37 Fed. R. Serv. 2d 141, 1983 U.S. Dist. LEXIS 19566
CourtDistrict Court, W.D. Pennsylvania
DecidedFebruary 2, 1983
DocketCiv. A. No. 82-283
StatusPublished
Cited by5 cases

This text of 100 F.R.D. 7 (Strawhecker v. Laurel School District) is published on Counsel Stack Legal Research, covering District Court, W.D. Pennsylvania primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Strawhecker v. Laurel School District, 100 F.R.D. 7, 37 Fed. R. Serv. 2d 141, 1983 U.S. Dist. LEXIS 19566 (W.D. Pa. 1983).

Opinion

MEMORANDUM OPINION

BLOCH, District Judge.

Plaintiff, Darlene Strawhecker, brings this action against defendants, the Laurel School District and its officials, pursuant to 28 U.S.C. §§ 1331, 1343(3), and 1343(4). Plaintiff claims that this action is cognizable under 42 U.S.C. § 1983 due to state action that has violated her constitutional rights. Plaintiff further claims that she. was terminated from her employment as bus driver for the Laurel School District on October 14, 1981, because she spoke openly and honestly, in public, on school bus safety matters. Specifically, plaintiff alleges that she has been denied equal protection and due process of law under the Fourteenth Amendment of the United States Constitution “because of the enforcement against her on an unfair and discriminatory basis of certain local customs, rules, policies and/or procedures of the defendant School District in such a manner as to restrict and exhibit her constitutional right to freedom of speech and freedom of expression with respect to school bus safety matters and to restrict and inhibit her constitutional right to make reasonable inquiries and openly disclose information and opinions concerning the same.” Finally, plaintiff contends that she was denied her right to a full and fair hearing before termination. She requests back pay and benefits, reinstatement, and costs of suit and attorney’s fees.

Plaintiff now moves for leave of this Court to file an amended complaint. The request seeks to add three additional claims to the complaint and to name additional parties.1 Plaintiff’s motion seeks to amend complaint in the following five ways: (1) to add the school district solicitor, individually and in his official capacity, as a defendant in the original claim and in the three new, proposed counts; (2) to request punitive damages in, and to further delineate factual details in support of, the original claim; (3) to add a second count to the complaint, which alleges a conspiracy among the original defendants and the school district solicitor in connection with the original claim; (4) to add a third count to the complaint against all but two of the original defendants, the school district solicitor, and three newly elected school board members, individually and in their official capacities, in connection with plaintiff’s termination hearing held, pursuant to an Order of the Court of Common Pleas of Lawrence County, Pennsylvania, in September of 1982; and (5) to add a fourth count to the original complaint, which alleges a conspiracy among the same defendants named in Count Three and in connection with the claims set forth in Count Three. The Court hereby grants plaintiff’s motion.

Motion for Leave to Amend

The pertinent provision for purposes of this Opinion is Fed.R.Civ.P. 15(a) which provides as follows:

(a) Amendments. A party may amend his pleading once as a matter of course at [10]*10any time before a responsive pleading is served or, if the pleading is one to which no responsive pleading is permitted and the action has not been placed upon the trial calendar, he may so amend it at any time within 20 days after it is served. Otherwise a party may amend his pleading only by leave of court or by written consent of the adverse party; and leave shall be freely given when justice so requires. A party shall plead in response to an amended pleading within the time remaining for response to the original pleading or within 10 days after service of the amended pleading, whichever period may be the longer, unless the court otherwise orders.

Since defendants have filed a responsive pleading,2 leave of Court is necessary.

In Foman v. Davis, 371 U.S. 178, 83 S.Ct. 227, 9 L.Ed.2d 222 (1962), the United States Supreme Court interpreted Rule 15(a) by stating:

If the underlying facts or circumstances relied upon by a plaintiff may be a proper subject of relief, he ought to be afforded an opportunity to test his claim on the merits. 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 allowance of the amendment, futility of amendment, etc. —the leave sought should, as the rules require, be ‘freely given.’ Of course, the grant or denial of an opportunity to amend is within the discretion of the district court, but outright refusal to grant the leave without any justifying reason appearing for the denial is not an exercise of discretion; it is merely abuse of that discretion and inconsistent with the spirit of the federal rules.

Id. at 182, 83 S.Ct. at 230. This Court has also interpreted Rule 15(a) by stating that the right to amend a pleading is addressed to the discretion of the district court, and great liberality in allowance of amendments is desired where it is necessary to bring about a furtherance of justice. Hirshhorn v. Mine Safety Appliances Co., 101 F.Supp. 549, 552 (W.D.Pa.1951), aff’d., 193 F.2d 489 (3d Cir.1952), cert. denied, 346 U.S. 866, 74 S.Ct. 105, 98 L.Ed. 376 (1953). However, the prescription of a liberal policy toward amendment of pleadings does not mean the absence of all restraint. Garrison v. Baltimore & Ohio Railroad Co., 20 F.R.D. 190, 194 (W.D.Pa.1957). Thus, the Court must exercise its discretion in light of the circumstances presented by the case at hand.

The primary reasons for the denial of leave to amend are as follows: (1) that the amendment will result in undue prejudice to the opposing party; (2) that the amendment has been unduly delayed; (3) that the amendment is not offered in good faith; and/or (4) that the movant has had sufficient opportunity to state a claim, but has failed to do so. 3 MOORE’S FEDERAL PRACTICE, ¶ 15.08[4], pp. 15-91—15-99 (1982). The most important question that the Court must address is whether the allowance of the amendment will prejudice or work an injustice upon any of the parties. Hirshhorn, supra, at 552. The aforementioned precedents will guide the Court in its review of plaintiff’s motion for leave to amend. To facilitate orderly discussion of plaintiff’s motion, the Court will address the motion in two separate sections — the first section will deal with plaintiff’s request to add additional claims, while the second section will address plaintiff’s proposal to add additional parties.

I. Addition of Claims

As stated, plaintiff’s proposed amended complaint seeks to add the following claims: (1) an addition of a claim for punitive damages in, and an addition of several paragraphs in support of, the original count of the complaint; (2) an addition of Count Two to the complaint, which charges a con[11]

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Bluebook (online)
100 F.R.D. 7, 37 Fed. R. Serv. 2d 141, 1983 U.S. Dist. LEXIS 19566, Counsel Stack Legal Research, https://law.counselstack.com/opinion/strawhecker-v-laurel-school-district-pawd-1983.