Stotesbery v. Muy Pizza-Tejas, LLC, 0:22-cv-01622

Plaintiff John Stotesbery, a Pizza Hut delivery driver, brought an FLSA collective action alleging wage and hour violations for inadequate reimbursement of vehicle expenses, seeking to represent a nationwide class.
After motions to dismiss, the District of Minnesota court limited the case to Minnesota drivers, finding no personal jurisdiction for out-of-state claims against defendants with insufficient forum contacts.
Plaintiff settled claims against the Muy Defendants for Minnesota drivers; subsequent nationwide claims were advanced in a new Georgia lawsuit using a consent-by-registration jurisdiction theory.
Plaintiff moved to amend the Minnesota complaint to reassert nationwide claims, arguing corporate consent to general jurisdiction in Minnesota through business registration.
The proposed amendment followed substantial delay, settlement of overlapping claims in Georgia and Texas, and multiple prior unsuccessful attempts to revisit jurisdictional rulings in this case.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Leave to amend to reintroduce nationwide claims	Amendment proper; new facts support nationwide jurisdiction	Resurrects dismissed claims; unfair delay and prejudice	Denied; amendment is unduly delayed and prejudicial
Consent theory via corporate registration	Registration in MN equals consent to general jurisdiction	Theory was available earlier; no new law or facts	Presented too late; not a valid reason for belated motion
Impact of parallel settlements	Texas/Georgia settlements do not moot this amendment	Amendments undermine settlement expectations and finality	Amendments would prejudice defendants; rejected
Timeliness of amendment	No undue delay; liberal standard for amendment applies	Significant delay; alternative avenues already pursued	Delay is undue; no sufficient justification

Kozlov v. Associated Wholesale Grocers, Inc., 818 F.3d 380 (8th Cir. 2016) (Rule 15 liberal policy favors amendments, but is not absolute)
Becker v. Univ. of Neb. at Omaha, 191 F.3d 904 (8th Cir. 1999) (no absolute right to amend under Rule 15)
Hartis v. Chicago Title Ins. Co., 694 F.3d 935 (8th Cir. 2012) (denial appropriate if undue delay or prejudice)
Vallone v. CJS Solutions Group, LLC, 9 F.4th 861 (8th Cir. 2021) (no FLSA nationwide jurisdiction without forum connection)
SPV-LS, LLC v. Transamerica Life Ins. Co., 912 F.3d 1106 (8th Cir. 2019) (reconsideration not for new legal theories available earlier)