Sampson v. Knight Transportation, Inc, 2:17-cv-00028

Valerie Sampson filed a putative class action on Oct. 14, 2016 on behalf of Washington-resident drivers alleging wage-and-hour violations (minimum wage, rest breaks, unlawful deductions, time records) against Knight Transportation, Inc.
Sampson worked for Knight Dry Van; depositions revealed two related entities—Knight Refrigerated, LLC and Knight Port Services, LLC—that employ Washington drivers and share corporate officers, payroll department, and payroll system.
After deposing Knight’s COO (Kevin Quast) on Aug. 2, 2017, Sampson moved to amend to add David Raymond (a former Port Services/Refrigerated driver) as a class representative and to add Refrigerated and Port Services as defendants.
There was no deadline for amended pleadings in the case schedule; class-certification briefing deadlines were extended by stipulation and had not passed.
Knight opposed, arguing undue delay, prejudice, and that joinder should be evaluated under Rule 20 rather than Rule 15; Knight also contested relation back under Rule 15(c).
The court granted leave to amend, concluding Rule 15 governs, no undue delay or prejudice, joinder would also satisfy Rule 20, and Raymond’s claims relate back to the original complaint.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether amendment to add a plaintiff and two defendants should be allowed	Amendment is timely; learned new facts at deposition; adding parties promotes efficiency and avoids duplicative litigation	Amendment is prejudicial, delayed, and joinder should fail under Rule 20	Granted under Rule 15; no bad faith, undue delay, futility, or prejudice; amendment allowed
Whether Rule 16 "good cause" standard applies	Scheduling order had no amended-pleading deadline, so Rule 15 governs	Argued implicitly that scheduling concerns should bar amendment	Rule 16 not implicated because motion was timely and did not violate any scheduling order
Whether permissive joinder under Rule 20 would permit adding Raymond, Refrigerated, and Port Services	Claims arise from same series of transactions and present common questions of law/fact	Joinder improper under Rule 20	Even under Rule 20, joinder permitted: factual overlap and common legal issues satisfied
Whether Raymond’s claims relate back to the filing date under Rule 15(c)(1)(C)	Defendants (via COO Quast) had notice and should have known employees could be in the class; relation back is appropriate	Implied contention that defendants lacked requisite notice or that plaintiff’s mistake precludes relation back	Relation back granted: defendants (through COO) knew of suit and that claims could have been brought against them; no prejudice shown

Eminence Capital, LLC v. Aspeon, Inc., 316 F.3d 1048 (9th Cir. 2003) (leave to amend is to be applied with extreme liberality)
United States v. Corinthian Colleges, 655 F.3d 984 (9th Cir. 2011) (factors for denying leave to amend)
Johnson v. Mammoth Recreations, 975 F.2d 604 (9th Cir. 1992) (Rule 16 good-cause standard for modifying scheduling orders)
Krupski v. Costa Crociere S.p.A., 560 U.S. 538 (2010) (relation-back under Rule 15(c)(1)(C) depends on what the added party knew or should have known)
Nelson v. Adams USA, Inc., 529 U.S. 460 (2000) (amendments adding adverse parties may be made under Rule 15)
Union Pac. R. Co. v. Nev. Power Co., 950 F.2d 1429 (9th Cir. 1991) (amendments adding claims are favored over amendments adding parties)
Lockheed Martin Corp. v. Network Solutions, Inc., 194 F.3d 980 (9th Cir. 1999) (prejudice from amendment shown by delay and need for additional discovery)
Coughlin v. Rogers, 130 F.3d 1348 (9th Cir. 1997) (Rule 20 joinder test for plaintiffs)
Visendi v. Bank of Am., N.A., 733 F.3d 863 (9th Cir. 2013) (same-transaction requirement for permissive joinder)
League to Save Lake Tahoe v. Tahoe Reg. Planning Agency, 558 F.2d 914 (9th Cir. 1972) (Rule 20 construed liberally to promote convenience and avoid multiple lawsuits)