Hudgens v. PROSPER, INC., 2010 UT 68

Hudgens, Prosper employee supervised by Christopherson, participated in a waterboarding-like exercise on May 29, 2007, during which he was restrained and unable to breathe while water was poured on his mouth and nose.
Prosper allegedly encouraged Christopherson's abusive management practices to boost sales, with prior incidents including marking employees and chancellor-like paddling, which Prosper allegedly tolerated.
Hudgens reported the incident to Prosper's HR, but Prosper took no action before Hudgens quit, citing resulting sleep problems, anxiety, depression, and physical symptoms; Hudgens seeks medical/psychological treatment and damages.
Hudgens filed January 15, 2008 complaint alleging four claims: common law assault and battery, intentional infliction of emotional distress, wrongful termination, and intentional interference with contract.
Prosper moved to dismiss, arguing WCA exclusivity bars tort claims (with Helf v. Chevron informing the exception analysis) and that wrongful termination lacks public policy support; Hudgens sought leave to amend in response.
District court dismissed the complaint without prejudice on July 23, 2008, denied leave to amend for procedural reasons, and later entered an order dismissing with prejudice after Prosper sought to tailor the order; Hudgens sought leave to amend again.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Did the district court abuse its discretion by denying leave to amend without adequate reasoning?	Hudgens argues denial lacked stated reasons, violating Rule 15(a) liberal amendment standard.	Prosper contends amendments would be futile or inconsistent with prior record, justifying denial.	Yes; district court abused discretion; remanded to grant leave to amend.

Helf v. Chevron U.S.A., Inc., 2009 UT 11 (Utah 2009) (intentional injury exception to workers' compensation exclusivity guidance)
Aurora Credit Servs., Inc. v. Liberty W. Dev., Inc., 970 P.2d 1273 (Utah 1998) (necessity of specifying grounds for denial of leave to amend; record must reflect reasoning)
Norman v. Arnold, 2002 UT 81 (Utah 2002) (liberal allowance of amendment; constraints when prejudice or futility)
Swan Creek Vill. Homeowners Ass'n v. Warne, 2006 UT 22 (Utah 2006) (abuse of discretion review for denial of leave to amend when reasoning is opaque)
Brown v. Div. of Water Rights, 2010 UT 14 (Utah 2010) (standard for evaluating dismissed claims and allowable factual proof)
Berneau v. Martino, 2009 UT 87 (Utah 2009) (context for procedural posture and merits related to amendment)
Foman v. Davis, 371 U.S. 178 (U.S. 1962) (liberal amendment standard; denial must be justified)