Wells v. Sanofi S.A.
- Proceeding
- district
- Area
- civil
- Panel
- Janis L. Sammartino (author)
Analysis
The court considered the parties' joint request to stay the case for six months to finalize a settlement and the plaintiff's motion for leave to amend the complaint. The court granted a 90-day stay, vacated deadlines, and denied the motion to amend without prejudice.
| What the court decided | The model |
|---|---|
Stay of proceedings granted for 90 days“In the interest of efficiency, therefore, the Court GRANTS IN PART the Parties’ Notice, VACATES all pending deadlines, and STAYS this action for ninety (90) days.” | agree with court The court applied the CMAX factors and found that a stay served judicial economy and fairness, particularly given the parties' agreement to settle. The reduction from six months to 90 days is a reasonable exercise of discretion to ensure the stay is not indefinite, consistent with the requirement that the stay be for a reasonable time. |
Plaintiff's Motion for Leave to Amend Complaint denied without prejudice“Finally, given the Parties’ intention to settle this case, the Court DENIES WITHOUT PREJUDICE Plaintiffs’ Motion for Leave to Amend Complaint.” | agree with court Denying a motion without prejudice when the case is being stayed for settlement is a standard procedural mechanism to avoid unnecessary litigation on the merits while the settlement is finalized. It preserves the plaintiff's right to refile the motion if the settlement falls through. |
The order itself: sound — The order correctly identifies the relevant legal standards for a stay of proceedings, citing both the broad discretion of the district court and the specific factors from CMAX, Inc. v. Hall. The application of these factors to the facts (mutual desire to settle, minimal damage from stay, avoidance of unnecessary costs) is logical. The court appropriately modified the requested duration to ensure the stay was not indefinite, adhering to the principle that stays should be for a reasonable time. The denial of the motion to amend without prejudice is procedurally sound given the context of a pending settlement.
Opinion
1 2 3 4 5 6 7 8 UNITED STATES DISTRICT COURT 9 SOUTHERN DISTRICT OF CALIFORNIA 10 11 RACHAEL WELLS, Case No.: 23-CV-2134 JLS (BLM)
12 Plaintiff, ORDER: (1) STAYING CASE; (2) 13 v. VACATING DEADLINES; AND (3) DENYING WITHOUT PREJUDICE 14 SANOFI S.A.; AVENTIS PHARMA PLAINTIFF’S MOTION FOR S.A.; SANOFI US SERVICES INC. f/k/a 15 LEAVE TO AMEND COMPLAINT SANOFI-AVENTIS U.S. INC.; SANOFI- 16 AVENTIS U.S. LLC; HOSPIRA (ECF Nos. 19, 24) WORLDWIDE, LLC f/k/a HOSPIRA 17 WORLDWIDE, INC.; HOSPIRA, INC.; 18 PFIZER, INC., 19 Defendants. 20 21 Presently before the Court is Plaintiff Rachael Wells’ Motion for Leave to Amend 22 Complaint (“Mot.,” ECF No. 19) and the Parties’ Notice of Settlement and Request to Stay 23 Proceedings (“Not.,” ECF No. 24). The Parties indicate that they have “reached an 24 agreement in principle for the complete resolution of this matter.” Not. at 1. As they 25 finalize a master settlement agreement resolving this case and other cases in multi-district 26 litigation, the Parties “respectfully request that this Court vacate all pending deadlines and 27 stay this matter for six months.” Id. 28 / / / 1 A district court “may, with propriety, find it is efficient for its own docket and the 2 fairest course for the parties to enter a stay of an action before it, pending resolution of 3 independent proceedings which bear upon the case.” Leyva v. Certified Grocers of Cal., 4 Ltd., 593 F.2d 857, 863 (9th Cir. 1979). District courts have “broad discretion to stay 5 proceedings.” Clinton v. Jones, 520 U.S. 681, 706 (1997). Granting a stay “is appropriate 6 when it serves the interests of judicial economy and efficiency.” Rivers v. Walt Disney 7 Co., 980 F. Supp. 1358, 1360 (C.D. Cal. 1997). 8 The Ninth Circuit described the factors that a district court must consider when 9 determining whether to grant a stay in CMAX, Inc. v. Hall: 10 Where it is proposed that a pending proceeding be stayed, the competing interests which will be affected by the granting or 11 refusal to grant a stay must be weighed. Among these competing 12 interests are the possible damage which may result from the granting of a stay, the hardship or inequity which a party may 13 suffer in being required to go forward, and the orderly course of 14 justice measured in terms of the simplifying or complicating of issues, proof, and questions of law which could be expected to 15 result from a stay. 16 17 300 F.2d 265, 268 (9th Cir. 1962). 18 The CMAX factors counsel in favor of a stay in this case. As both Parties seek to 19 stay this proceeding, the possible damage that could result from a stay is minimal. 20 Requiring the Parties to incur further litigation costs in a case that is likely to settle imposes 21 unnecessary hardship. Finally, enabling the Parties to finalize their settlement will obviate 22 the need for the Parties and the Court to litigate further, thus simplifying issues, proof, and 23 questions of law. The Court is thus persuaded that a stay is appropriate. 24 That said, the Court is mindful that “[a] stay should not be granted unless it appears 25 likely the other proceedings will be concluded within a reasonable time in relation to the 26 urgency of the claims presented to the court.” Leyva, 593 F.2d at 864. Here, the Parties 27 have not explained why they require six months to finalize their Master Settlement 28 Agreement. In the interest of efficiency, therefore, the Court GRANTS IN PART the 1 || Parties’ Notice, VACATES all pending deadlines, and STAYS this action for ninety (90) 2 ||days. The Parties SHALL FILE a joint status report at or before the expiration of the 3 || Court’s stay to apprise the Court of the status of the settlement and of this action. 4 Finally, given the Parties’ intention to settle this case, the Court DENIES 5 || WITHOUT PREJUDICE Plaintiffs’ Motion for Leave to Amend Complaint. 6 IT IS SO ORDERED. 7 || Dated: March 20, 2024 jae L. Lo memeaite- g on. Janis L. Sammartino 9 United States District Judge 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28