Otto v. Newfield Exploration Co.

2017 WL 3616712 (2017)

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Otto v. Newfield Exploration Co.

United States District Court for the District of Montana
2017 WL 3616712 (2017)

Facts

Blaine Otto died while inspecting an oil-storage tank in North Dakota for Newfield Exploration Co. (Newfield) (defendant). Otto’s estate (the estate) (plaintiff) filed suit against Newfield in federal court in Montana. The estate’s complaint included a claim for punitive damages under Montana law. The court determined North Dakota law applied, and the estate moved to amend its complaint to add a claim for punitive damages under North Dakota law. Federal law and North Dakota law conflicted on the standard for amending a pleading to add a claim for punitive damages. Under Federal Rule of Civil Procedure (FRCP) 15(a)(2), a court could grant a motion to amend a complaint freely if justice so required. Under North Dakota law, a complaint could be amended to add a claim for punitive damages only if the trier of fact could find that punitive damages were proved by a preponderance of the evidence.

Rule of Law

Issue

Holding and Reasoning (Watters, J.)

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