United States District Court, S.D. Indiana, Indianapolis Division
L. Pryor United States Magistrate Judge
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.
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,
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.
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
Prejudice and Tactical Disadvantage to the Non-Moving
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.
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.
Simplification of the Issues and Streamlining the Trial.
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.
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.
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 ...