Nelson v. Adams USA, Inc., et al. case brief

Nelson v. Adams USA, Inc., et al. case brief summary
529 U.S. 460 (2000)

CASE SYNOPSIS

Petitioner challenged a decision from the United States Court of Appeals for the Federal Circuit affirming the grant of respondent's motion to amend its pleadings to include petitioner as a party pursuant to Fed. R. Civ. P. 15. The decision simultaneously made petitioner a party and subjected him to judgment.

CASE FACTS
Corporation's action for patent infringement against respondent was dismissed and respondent was awarded costs and attorney fees. Respondent, fearful that corporation would be unable to pay, moved to amend its pleadings pursuant to Fed. R. Civ. P. 15 to include petitioner, president and sole shareholder of corporation, as a party. The court of appeals affirmed the decision simultaneously making petitioner a party and subjecting him to judgment.

DISCUSSION

• The court reversed and remanded the action because the district court should not have made petitioner personally liable when he was made a party. 
• The requirements of rule 15and the fundamental requisite of due process were not met because petitioner was never served with an amended pleading or given the opportunity to defend against the imposition of liability. 
• Petitioner was adjudged liable before he was afforded a proper opportunity to respond to the allegations against him.

CONCLUSION
The court reversed and remanded the action because petitioner should not have been made personally liable when he was made a party to the action. Fed. R. Civ. P. 15 requirements were not met because petitioner was never served an amended pleading or given the opportunity to contest his liability.

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