Request for Leave to Amend
Federal Rules of Civil Procedure
“Leave to amend is in no way automatic, but the district court must possess a substantial reason to deny a party’s request for leave to amend.” Weyerhaeuser Co. v. Burlington Ins. Co., 74 F.4th 275, 288 (5th Cir. 2023) (quoting Marucci Sports, L.L.C., 751 F.3d at 378). Under the “presumption in favor of allowing pleading amendments, courts of appeals routinely hold that a district court’s failure to provide an adequate explanation to support its denial of leave to amend justifies reversal.” Mayeaux, 376 F. 3d at 426. However, the district court’s failure to explain is not grounds for reversal when “justification for the denial is ʻreadily apparent’” on the record or “ample and obvious” on the record. Marucci Sports, L.L.C., 751 F.3d at 378 (quoting Mayeaux, 376 F.3d at 426). Here, we reverse the district court’s denial of leave to amend because we do not see obvious grounds for denial, and the district court gave no explanation for its finding that there was no good cause to amend. Our court has generally held that district courts should consider numerous factors when determining whether to grant leave to amend, including “1) undue delay, 2) bad faith or dilatory motive, 3) repeated failure to cure deficiencies by previous amendments, 4) undue prejudice to the opposing party, and 5) futility of the amendment.” Smith v. EMC Corp., 393 F.3d 590, 595 (5th Cir. 2004); see also SGK Props., L.L.C. v. U.S. Bank Nat’l Ass’n, 881 F.3d 933, 944 (5th Cir. 2018); Weyerhaeuser, 74 F.4th at 288. CH Offshore discusses these factors in its brief on appeal, but Mexiship Texas neglects to respond with any specificity. Because any one of these factors may have provided the basis of the district court’s denial for lack of good cause, we take each in turn briefly to confirm whether any such factor provides an obvious basis for denial.
(U.S. Court of Appeals for the Fifth Circuit, Dec. 19, 2025, CH Offshore v. Mexiship Ocean, Docket No. 24-20525)
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