Stewart v. Shelby Tissue, Inc.
United States District Court for the Western District of Tennessee
189 F.R.D. 357 (W.D. Tenn. 1999)
After resigning from Shelby Tissue (defendant) and immediately suing, Dennis Stewart (plaintiff) began working for a competitor, Kruger; the defendants sent letters to both Stewart and Kruger asserting his new job violated a noncompete clause, and Kruger fired him. Without first seeking the court's permission, Stewart filed an amended complaint adding claims for unlawful inducement of breach of contract and tortious interference -- claims based entirely on conduct occurring after his original complaint. He then moved for leave to file these additional counts, and the defendants objected.
Whether, under Federal Rule of Civil Procedure 15(a), a party may amend his pleadings to add new claims that arose after the original pleadings were filed.