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Estimating Group LLC v. Rickey Conradt, Inc.

United States District Court, S.D. Indiana, Indianapolis Division

July 3, 2019



          Doris L. Pryor United States Magistrate Judge

         This matter comes before the Court on the Defendants' Motion to Stay Litigation Until the Court Decides Motion to Dismiss (Dkt. 16). The Plaintiff filed its response on April 23, 2019. The Motion was referred to the Undersigned for ruling and, for the reasons that follow, is hereby GRANTED IN PART and DENIED IN PART.

         I. Legal Standard

         District courts have the inherent power to control their docket and, as such, enjoy broad discretion when determining whether to stay proceedings. Clinton v. Jones, 520 U.S. 681, 706-07 (1997); Landis v. N. Am. Co., 299 U.S. 248, 254 (1936). When considering a motion to stay, the Court must consider the need for the stay and the parties' competing interests, Landis, 299 U.S. at 254-55. The proponent of the stay has the burden of establishing the need for the motion. Clinton, 520 U.S. at 708 (citing Landis, 299 U.S. at 255). This Court uses the following three factors to determine if a stay is warranted: “(1) whether a stay will unduly prejudice or tactically disadvantage the non-moving party; (2) whether a stay will simplify the issues in question and streamline the trial; and (3) whether a stay will reduce the burden of litigation on the parties and the Court.” Irving Materials, Inc. v. Zurich Am. Ins. Co., No. 1:03-cv-0361-SEB-TAB, 2008 WL 1971468, at *2 (S.D. Ind. May 5, 2008). Magistrate judges have the authority to rule on motions to stay. See Indiana Pine LLC v. Ponsse USA, Inc., No. IP99-0123-C-Y/F, 1999 WL 1866849, at * 1 (S.D. Ind. Mar. 30, 1999).

         Generally, courts are reluctant to stay litigation “because [it] bring[s] resolution of the dispute to a standstill.” Am. Senior Communities, LLC v. Burkhart, No. 1:17-cv-03273-TWP-DML, 2019 WL 415614, at *2 (S.D. Ind. Feb. 1, 2019).

         II. Discussion

         The Defendants request that this Court stay these proceedings because their pending Motion to Dismiss hinges upon the dispositive threshold issue of personal jurisdiction and, therefore, argue that all three factors weigh in favor of staying this case. The Plaintiff maintains that the Defendants are not entitled to a stay merely because they raised a jurisdictional argument and, moreover, none of the three factors that the Court is to consider weigh in favor of granting the stay. The Court will address each factor in turn.[1]

         A. Prejudice and Tactical Disadvantage to the Non-Moving Party.

         First, Defendants maintain that their requested stay should be granted because it presents no prejudicial or tactical disadvantages to the Plaintiff. The Defendants argue that the requested temporary stay would not prejudice the Plaintiff because after the Court rules on the Motion to Dismiss the case would either proceed or be resolved. In response, the Plaintiff, the non-movant, asserts that it will be prejudiced by a stay because it will be prevented from resolving its claims in a speedy manner as outlined in Rule 1 of the Federal Rules of Civil Procedure.

         Plaintiff's argument rests solely on the fact that a stay would delay the adjudication of this case. To be sure, a stay would slow down the progression of this case and delay Plaintiff's right to proceed with its claim. The Court, however, is not persuaded that this short delay on its own constitutes undue prejudice. See Trading Techs Int'l, Inc. v. BCG Partners, Inc., 186 F.Supp.3d 870, 877 (N.D. Ill. 2016) (finding that in the context of staying litigation “the potential for delay does not, by itself, establish undue prejudice, ” but acknowledging that waiting for other processes to run their course “risks prolonging the final resolution of the dispute and thus may result in some inherent prejudice to the [non-movant].”) (internal quotations omitted); Cascades Comput. Innovation, LLC v. SK hynix Inc., No. 11 C 4356, 2012 WL 2086469, at *1 (N.D. Ill. May 25, 2012) (finding that a sixteen-month stay, without more, would not cause undue prejudice to the plaintiff). Moreover, the Plaintiff has failed to identify any tactical disadvantages that a stay would impose going forward. Accordingly, the Court finds that factor one weighs in favor of granting the Motion to Stay.

         B. Simplification of the Issues and Streamlining the Trial.

         In regard to factor two, the Defendants maintain that staying the case is necessary because it would simplify the issues and streamline the trial by preventing unnecessary motion practice and discovery requests. Plaintiff argues that granting a stay here would be akin to making a bright line rule that a stay is appropriate any time there is a pending motion to dismiss.

         The factor two analysis generally rests on whether there are outside proceedings that have some bearing on the matter sought to be stayed. Knauf Insulation, LLC v. Johns Manville Corp., No. 1:15-cv-00111-WTL-MJD, 2015 WL 7084079, at *3-4 (S.D. Ind. Nov. 13, 2015); Cook Inc. v. Endologix, Inc., No. 1:09-cv-1248-WTL-TAB, 2010 WL 325960, at *2 (S.D. Ind. Jan. 21, 2010); Irving Materials, Inc., 2008 WL 1971468, at *2. In Knauf Insulation, this Court found that factor two weighed in favor of granting a stay because the Patent and Trademark Office (“PTO”) had started reviewing a patent at issue in the case, and the PTO's review would likely affect the litigation going forward. Knauf Insulation, 2015 WL 7084079, at *3-4. Similarly, in Cook this Court found that factor two weighed in favor of granting a stay because the PTO's pending reexamination of patents at issue in the litigation would potentially reduce the number of claims and issues before the Court and guide its analysis at the summary judgment stage. Cook, 2010 WL 325960, at *2. Likewise, in Irving Materials, this Court reluctantly stayed the resolution of a sanctions motion, in part because it found that the parties' arbitration proceedings might help simplify the issues before the court. Irving Materials, 2008 WL 1971468, at *2.

         Here, unlike the cases above, the Defendants have failed to identify any outside proceedings that would simplify or guide the Court's analysis of the substantive issues in these proceedings that would justify ...

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