## Facts

- Jerry A. Beeck was severely injured on July 15, 1972, while using a water slide at an Iowa recreational facility.
- The Beecks sued Aquaslide ’N’ Dive Corp. in federal court, alleging it designed, manufactured, and sold the slide, asserting negligence, strict liability, and implied warranty.
- Aquaslide’s insurer and investigators initially concluded the slide was Aquaslide’s, and Aquaslide’s answer (Dec. 17, 1973) admitted manufacture.
- The personal-injury limitations period expired on July 15, 1974.
- After the limitations period ran, Aquaslide’s president inspected the slide and determined it was not manufactured, designed, or sold by Aquaslide.
- Aquaslide moved to amend its answer to deny manufacture; the Beecks opposed, arguing prejudice because they could no longer sue the actual manufacturer.
- The district court allowed the amendment and ordered a separate jury trial limited to whether Aquaslide designed, manufactured, or sold the slide.
- The jury found Aquaslide did not design, manufacture, or sell the slide, and the district court dismissed the case.

## Issues

1. Whether the district court abused its discretion under Federal Rule of Civil Procedure 15(a) by allowing Aquaslide to amend its answer to withdraw an admission and deny manufacture after the statute of limitations had expired.
2. Whether the district court abused its discretion under Federal Rule of Civil Procedure 42(b) by ordering a separate trial limited to the threshold issue of whether Aquaslide designed, manufactured, or sold the slide.

## Decision

- The court of appeals affirmed.
- The district court did not abuse its discretion in granting leave to amend under Rule 15(a).
- The district court did not abuse its discretion in ordering a separate trial on manufacturer identity under Rule 42(b).
- Because the jury found Aquaslide was not involved in designing, manufacturing, or selling the slide, dismissal of the action against Aquaslide was upheld.

## Legal Principles

- Rule 15(a) amendments should be freely permitted when justice requires, and the decision rests largely within the trial court’s discretion.
- In evaluating leave to amend, courts focus on factors such as bad faith, undue delay, and prejudice to the opposing party.
- Prejudice from an amendment is not established merely because the statute of limitations has run; the trial court may consider whether asserted harm is concrete or speculative.
- A court may allow an amendment withdrawing an earlier admission when the admission resulted from a reasonable mistake and the movant acts promptly upon discovering the error.
- Rule 42(b) permits separate trials of discrete issues to further convenience, avoid prejudice, and conserve judicial resources, subject to the trial court’s discretion.
- Bifurcation is appropriate where a threshold, potentially dispositive issue (such as defendant identity as manufacturer/seller) is separable from defect, causation, and damages, and where the opposing party’s ability to present the issue is not materially impaired.

## Conclusion

The court upheld the trial court’s discretionary rulings allowing a defendant to correct a mistaken admission of manufacture and to try manufacturer identity separately, emphasizing the absence of bad faith, limited and uncertain prejudice to plaintiffs, and the efficiency and fairness of resolving a dispositive threshold issue first.


Beeck v. Aquaslide ’N’ Dive Corp., 562 F.2d 537 (8th Cir. 1977)