Ciabattoni v. Teamsters Local 326
N15C-04-059 VLM
| Del. Super. Ct. | Jul 25, 2017Background
- Plaintiff sued Teamsters Local 326 (and others) for claims including defamation, invasion of privacy, and intentional infliction of emotional distress based on postings and alleged disclosure of documents spanning 2012–Jan. 9, 2015.
- On Feb. 12, 2017 a Facebook comment and photo (purportedly showing Ernie Soehl with Travis Eby) was discovered; Plaintiff says it reveals a broader conspiracy and seeks to join several out-of-state defendants (Soehl, IBT, Teamsters Locals 701 & 776, Robert Baker) and rejoin Eby via a proposed third amended complaint.
- Defendants moved to oppose joinder, arguing lack of personal jurisdiction, statute of limitations, futility, prejudice, and that Plaintiff improperly seeks to relitigate dismissed issues.
- Plaintiff invoked traditional and conspiracy-based personal jurisdiction theories, Rule 15 amendment-relate-back under Rule 15(c), and argued amendments were necessary for complete relief (including retractions/apologies).
- The Court found the Facebook post immaterial to prior jurisdictional rulings, concluded the proposed amendment would be futile, and denied leave to file the third amended complaint and to (re)join the new defendants.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Personal jurisdiction over out-of-state defendants via conspiracy theory | The newly discovered Facebook post shows Eby/Soehl connection and supports conspiracy-based jurisdiction over nonresident defendants | The post does not change prior minimum-contacts analysis; conspiracy theory insufficient without strict factual proof | Denied — post is immaterial; amendment futile because defendants likely subject to dismissal for lack of PJ |
| Rejoining Eby after dismissal (relitigation) | Evidence discovered justifies reincluding Eby | Law of the case and procedural rules preclude a third attempt to relitigate dismissed jurisdictional issue | Denied — law of the case bars relitigation; Facebook post is not new, decisive evidence |
| Statute of limitations / relation back under Rule 15(c) | Claims against new defendants relate back to original complaint through same conduct and conspiracy; new parties had notice | No misidentification in original complaint; no showing new defendants knew or should have known of suit within limitations period | Denied — Plaintiff failed Rule 15(c) showing; amendment would be time-barred and futile |
| Leave to amend / futility and delay | Amendments should be freely granted when justice requires; necessary for complete relief | Amendment is futile, prejudicial, and would unduly delay case already pending >2 years with little discovery | Denied — amendment futile, would cause undue delay; court emphasized need to proceed with discovery instead of repeated pleadings |
Key Cases Cited
- Clark v. State Farm Mut. Auto. Ins. Co., 131 A.3d 806 (Del. 2016) (futility standard for leave to amend)
- Price v. E.I. DuPont de Nemours & Co., 26 A.3d 162 (Del. 2011) (standards applied in amendment/futility analysis)
- Mullen v. Alarmguard of Delmarva, Inc., 625 A.2d 258 (Del. 1993) (discussing relation-back requirements for adding new parties)
- Nationwide Emerging Managers, LLC v. Northpointe Holdings, LLC, 112 A.3d 878 (Del. 2015) (discussing law-of-the-case doctrine)
- Istituto Bancario Italiano, SpA v. Hunter Eng'g Co., Inc., 449 A.2d 210 (Del. 1982) (limitations on relation-back and joinder when new-party notice is lacking)
- Old Dominion Branch No. 496, Nat'l Ass'n of Letter Carriers v. Austin, 418 U.S. 264 (U.S. 1974) (union/First Amendment context cited by defendants)
- Linn v. United Plant Guard Workers of Am., Local 114, 383 U.S. 53 (U.S. 1966) (union-related precedent cited)
- Coronado Coal Co. v. United Mine Workers of Am., 268 U.S. 295 (U.S. 1925) (union tort/conspiracy principles cited)
- United Mine Workers of Am. v. Coronado Coal Co., 259 U.S. 344 (U.S. 1922) (earlier union-conspiracy authority cited)