Edwards v. Safeway, Inc., 216 A.3d 17

On March 9, 2014, Fiona Edwards was detained, physically confronted, and accused of shoplifting at a Safeway; she alleged loss of property and multiple intentional torts.
After partly successful summary judgment on statute-of-limitations grounds, only a conversion claim remained against Safeway.
Safeway filed a written admission of liability for conversion and moved to exclude a surveillance video showing the incident; the trial court accepted the admission and excluded the video and any evidence of liability.
Edwards sought punitive damages and requested a jury instruction on punitives; the trial court repeatedly barred her from presenting evidence or instruction on punitive damages and limited her to compensatory damages evidence.
Shortly before trial (after discovery closed), Edwards moved to amend her complaint to add negligence claims; the trial court denied the motion as untimely. The jury awarded Edwards the compensatory relief she sought.
On appeal, the court affirmed the denial of the amendment but held the trial court abused its discretion in barring evidence and a jury instruction on punitive damages and remanded for further proceedings on that issue.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the trial court abused its discretion in denying Edwards' motion to amend to add negligence claims	Amendment was justified in the interest of justice and should be allowed under Rule 15	Motion was untimely (filed after discovery closed and shortly before trial) and would prejudice Safeway by requiring new discovery	Denial affirmed: court did not abuse its discretion given lateness, length of case, lack of satisfactory reason, and likely prejudice to Safeway
Whether the trial court erred in excluding evidence (surveillance video and testimony) and a punitive-damages instruction because Safeway had admitted liability	Edwards argued the manner of conversion was relevant to punitive damages and she was entitled to present evidence and request an instruction	Safeway argued its admission of liability rendered evidence of how conversion occurred irrelevant and unduly prejudicial	Reversed: admission of liability does not preclude evidence relevant to punitive damages; manner of conversion is material to punitive claim and Edwards should have been allowed to present such evidence and request an instruction

Crowley v. N. Am. Telecomm. Ass’n, 691 A.2d 1169 (D.C. 1997) (standards for amending pleadings under Rule 15 and appellate review of denial)
Eagle Wine & Liquor Co. v. Silverberg Elec. Co., 402 A.2d 31 (D.C. 1979) (appellate review of denial of motion to amend requires valid ground)
Pannell v. District of Columbia, 829 A.2d 474 (D.C. 2003) (factors for evaluating tardy motion to amend: timing, prejudice, merit, bad faith)
Mason v. Rostad, 476 A.2d 662 (D.C. 1984) (punitive damages in conversion where conduct is reckless, willful, or aggravated)
Croley v. Republican Nat’l Comm., 759 A.2d 682 (D.C. 2000) (triable issue for punitive damages requires evidence from which jury could find malicious intent or willful disregard)
Campbell v. Fort Lincoln New Town Corp., Inc., 55 A.3d 379 (D.C. 2012) (standard of review for evidentiary rulings and legal determinations on appeal)
Tolson v. District of Columbia, 860 A.2d 336 (D.C. 2004) (appellate review and standards for punitive-damages evidentiary questions)
Johnson v. District of Columbia Rental Hous. Comm’n, 642 A.2d 135 (D.C. 1994) (judicial admissions and effect of stipulations)
Briggs v. Dalkon Shield Claimants Tr., 174 F.R.D. 369 (D. Md. 1997) (admissibility considerations after stipulation—focus on undue prejudice and waste of time rather than absolute exclusion)