Automated Summary
Key Facts
Plaintiff Tracy Pitts, as Guardian Ad Litem for Mary Pitts, filed a First Amended Complaint against Defendant Unilab Corporation d/b/a Quest Diagnostics. On August 19, 2025, Quest filed a motion for judgment on the pleadings regarding Plaintiff's prayer for punitive damages. Plaintiff agreed to dismiss her claim for punitive and exemplary damages against Quest. The Court construed this stipulation as a motion to amend the First Amended Complaint under Federal Rule of Civil Procedure 15(a)(2) and granted it. The Court also granted Quest's request to withdraw its motion for judgment on the pleadings.
Issues
Whether to grant Plaintiff's motion to amend the First Amended Complaint to dismiss her claim and prayer for punitive and exemplary damages against Defendant Quest Diagnostics, and whether to construe the stipulation as a motion to amend under Federal Rule of Civil Procedure 15(a)(2).
Holdings
The court granted Plaintiff's construed motion to amend the First Amended Complaint to withdraw claims for punitive and exemplary damages against Defendant Quest Diagnostics. The court also granted Defendant Quest Diagnostics' request to withdraw its motion for judgment on the pleadings as a result of the Plaintiff's withdrawal of the punitive damages claim.
Remedies
- Defendant Quest Diagnostics' motion for judgment on the pleadings as to Plaintiff's prayer for punitive damages is granted and withdrawn from the Court's calendar.
- The Court granted Plaintiff's construed motion to amend the First Amended Complaint under Federal Rule of Civil Procedure 15(a)(2), allowing withdrawal of the claim and prayer for punitive and exemplary damages against Defendant Quest Diagnostics.
- Plaintiff's claim and prayer for punitive and exemplary damages against Defendant Quest Diagnostics in the First Amended Complaint are withdrawn with prejudice.
Legal Principles
The court applied Federal Rule of Civil Procedure 15(a)(2) to construe the plaintiff's stipulation to dismiss punitive damages claims as a motion to amend the complaint, citing the policy that amendments should be applied with extreme liberality when a party is eliminating an issue or claims but not completely dismissing a defendant.
Precedent Name
- C.F. v. Capistrano Unified School District
- Hells Canyon Pres. Council v. U.S. Forest Serv.
Cited Statute
Federal Rules of Civil Procedure
Judge Name
Helena M. Barch-Kuchta
Passage Text
- The Court construes Plaintiff's stipulation to dismiss her claim and prayer for punitive and exemplary damages as to Defendant Quest as a motion to amend her First Amended Complaint under Federal Rule of Civil Procedure 15(a)(2). Hells Canyon Pres. Council v. U.S. Forest Serv., 403 F.3d 683, 687 (9th Cir. 2005) (Rule 15(a) "is appropriate mechanism" when party is eliminating an issue or one or more claims but not completely dismissing a defendant).
- 1. Plaintiff's construed motion to amend (Doc. No. 47) is GRANTED. 2. Plaintiff's claim and prayer for punitive and exemplary damages against Defendant Quest Diagnostics in the First Amended Complaint (Doc. No. 28) are WITHDRAWN. 3. Defendant Quest Diagnostics' request to withdraw its motion for judgment on the pleadings as to Plaintiff's prayer for punitive damages in the First Amended Complaint (Doc. No. 48) is GRANTED and Defendant Quest's motion (Doc. No. 45) is WITHDRAWN.