Somascan, Inc. v. Philips Medical Systems Nederland, B.V., 714 F.3d 62

Somascan, Inc. and affiliated entities sued Philips Medical Systems Nederland, B.V. in Puerto Rico federal court for misrepresentation of medical equipment and quality.
The district court set a scheduling order with a deadline to amend pleadings (December 30, 2009).
Philips moved for summary judgment on July 2011; Somascan sought leave to amend two days later (July 30, 2011), adding new claims and a new defendant and changing jurisdictional basis.
Somascan’s motion to amend was filed seventeen months after the deadline and without a showing of good cause for delay.
The district court denied the motion to amend and later granted summary judgment for Philips; the case was dismissed March 26, 2012.
On appeal, the First Circuit reviews a Rule 16(b) good cause denial for abuse of discretion and affirms if the record shows any adequate reason for denial.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the district court abused its discretion denying leave to amend.	Somascan contends good cause existed for late amendment.	Philips argues no good cause and undue delay; amendment would be futile after discovery and summary judgment.	No abuse of discretion; denial affirmed.

Hatch v. Department for Children, Youth & Their Families, 274 F.3d 12 (1st Cir. 2001) (supports that delay affects denial of leave to amend after discovery)
Steir v. Girl Scouts of the USA, 383 F.3d 7 (1st Cir. 2004) (delay and prejudice considerations in Rule 16(b) good cause)
Acosta-Mestre v. Hilton International of Puerto Rico, Inc., 156 F.3d 49 (1st Cir. 1998) (late amendments are disfavored; prejudice and diligence matter)
Resolution Trust Corp. v. Gold, 30 F.3d 251 (1st Cir. 1994) (amendment must be grounded in the record and substantial evidence)
Trans-Spec Truck Serv. v. Caterpillar Inc., 524 F.3d 315 (1st Cir. 2008) (standard for good cause governed by Rule 16(b))