Sean Thompson-El v. Jimmy Jones, Superintendent Dick Moore, Theresa Thornburg, 876 F.2d 66 (8th Cir. 1989). · Go Syfert
Sean Thompson-El v. Jimmy Jones, Superintendent Dick Moore, Theresa Thornburg, 876 F.2d 66 (8th Cir. 1989). Cases Citing This Book View Copy Cite
204 citation events (116 in the last 25 years) across 17 distinct courts.
Strongest positive: Shantae Winston, individually and on behalf of Carlton Bernard, deceased v. City of St. Louis, Missouri, et al. (moed, 2026-02-23) · Strongest negative: Twin City Construction Co. Of Fargo v. Turtle Mountain Band Of Chippewa Indians (ca8, 1990-08-13)
Treatment trajectory · 1990 → 2026 · click a year to view as-of
1990 2008 2026
Top citers, strongest first. 50 distinct citers. How cited ↗
discussed Cited "but see" Twin City Construction Co. Of Fargo v. Turtle Mountain Band Of Chippewa Indians
8th Cir. · 1990 · signal: but cf. · confidence high
But cf. Thompson-El v. Jones, 876 F.2d 66 , 67 n. 3 (8th Cir.1989) (district court's failure to articulate reasons for denial of motion to amend not good practice, but not per se abuse of discretion). 13 Although the district court may have reached the proper conclusion, it is hard to tell without an explanation for the action taken.
discussed Cited "but see" Twin City Construction Co. v. Turtle Mountain Band of Chippewa Indians ex rel. LaFromboise
8th Cir. · 1990 · signal: but cf. · confidence high
But cf. Thompson-El v. Jones, 876 F.2d 66 , 67 n. 3 (8th Cir.1989) (district court’s failure to articulate reasons for denial of motion to amend not good practice, but not per se abuse of discretion).
examined Cited as authority (verbatim quote) Shantae Winston, individually and on behalf of Carlton Bernard, deceased v. City of St. Louis, Missouri, et al.
E.D. Mo. · 2026 · signal: see · quote attribution · 1 verbatim quote · confidence high
absent a good reason for denial-such as undue delay, bad faith or dilatory motive, repeated failure to cure deficiencies by amendments previously allowed, undue prejudice to the non-moving party, or futility of amendment-leave to amend should be granted.
discussed Cited as authority (verbatim quote) Phyllis Schlafly Revocable Trust, et al. v. Anne Cori
E.D. Mo. · 2025 · signal: see, e.g. · quote attribution · 1 verbatim quote · confidence high
the policy favoring liberal allowance of amendment does not mean that the right to amend is absolute.
examined Cited as authority (verbatim quote) Haukaas v. Liberty Mutual Insurance Company (4×) also: Cited as authority (rule), Cited "see"
D.S.D. · 2022 · signal: see · quote attribution · 1 verbatim quote · confidence high
the additional burdens of discovery and delay the amendment would have placed on defendants we are unwilling to characterize as insignificant prejudice, especially in light of plaintiff's inability to provide a valid excuse for his failure to act earlier.
discussed Cited as authority (rule) JLK Construction, LLC v. Alva Advance, LLC; Jared Leff; SKD Holdings, LLC; Boost Capital Group, LLC; Zac Bena
Bankr. W.D. Mo. · 2025 · confidence medium
Thompson-El v. Jones, 876 F.2d 66, 67 (8th Cir. 1989). “[D]ismissal with prejudice is typically appropriate when a plaintiff has shown ‘persistent pleading failures’ despite one or more opportunities to amend.” Miles v. Simmons Univ., 514 F. Supp. 3d 1070 , 1080 (D.
cited Cited as authority (rule) North Fork Wind, LLC, et al. v. Knox County, Nebraska, et al.
D. Neb. · 2025 · confidence medium
Thompson-El v. Jones, 876 F.2d 66, 67 (8th Cir. 1989) (citing Foman v. Davis, 371 U.S. 178 (1962)).
discussed Cited as authority (rule) Gardner Standard Kentaurus Holdco, LLC v. Eaton
D. Minnesota · 2025 · confidence medium
The Eighth Circuit has held that although amendment of a pleading “should be allowed liberally to ensure that a case is decided on its merits . . . there is no absolute right to amend.” Ferguson v. Cape Girardeau County, 88 F.3d 647 , 650-51 (8th Cir. 1996) (citing Thompson-El v. Jones, 876 F.2d 66, 67 (8th Cir. 1989); Chesnut v. St.
discussed Cited as authority (rule) Smuda v. Marten
D. Minnesota · 2025 · confidence medium
The Eighth Circuit has held that although amendment of a pleading “should be allowed liberally to ensure that a case is decided on its merits . . . there is no absolute right to amend.” Ferguson v. Cape Girardeau Cnty., 88 F.3d 647 , 650-51 (8th Cir. 1996) (citing Thompson-El v. Jones, 876 F.2d 66, 67 (8th Cir. 1989); Chesnut v. St.
discussed Cited as authority (rule) Hemp Association of Louisiana v. Landry
M.D. La. · 2025 · confidence medium
(Doc. 68-1 at 2.) These consequences include rejections of previously approved labels, cease and desist orders, “retroactive restrictions on lawful commerce[,]” and “disruption of supply chains and retail operations.” (Id.) Moreover, Plaintiffs claim that the amended complaint “expands” their previous claims regarding the Commerce Clause and Due Process Clause, “providing additional factual and legal support . . . in light of how Act 752 has been applied in practice.” (Doc. 68 at ¶ 4.) These new facts include Plaintiff Cypress Hemp being forced to “pull products from store s…
discussed Cited as authority (rule) Prestby v. A&A Services, LLC
D. Neb. · 2025 · confidence medium
Courts have analyzed undue delays as “[w]hen a considerable amount of time has passed since the filing of a complaint and the motion to amend is made on the eve of trial and will cause prejudice and further delay… without some valid reason for the belatedness of the motion.” Thompson–El v. Jones, 876 F.2d 66, 67 (8th Cir. 1989).
discussed Cited as authority (rule) Dahir v. Bolin
D. Minnesota · 2025 · confidence medium
The Eighth Circuit has held that although amendment of a pleading “should be allowed liberally to ensure that a case is decided on its merits . . . there is no absolute right to amend.” Ferguson v. Cape Girardeau Cnty., 88 F.3d 647 , 650-51 (8th Cir. 1996) (citing Thompson-El v. Jones, 876 F.2d 66, 67 (8th Cir. 1989); Chesnut v. St.
discussed Cited as authority (rule) Babbit v. Target Corporation (2×) also: Cited "see"
D. Minnesota · 2025 · confidence medium
The Eighth Circuit has held that although amendment of a pleading “should be allowed liberally to ensure that a case is decided on its merits . . . there is no absolute right to amend.” Ferguson v. Cape Girardeau Cnty., 88 F.3d 647 , 650-51 (8th Cir. 1996) (citing Thompson-El v. Jones, 876 F.2d 66, 67 (8th Cir. 1989); Chesnut v. St.
discussed Cited as authority (rule) Kutz v. NGI Capital, Inc.
D. Minnesota · 2024 · confidence medium
The Eighth Circuit has held that although amendment of a pleading “should be allowed liberally to ensure that a case is decided on its merits . . . there is no absolute right to amend.” Ferguson v. Cape Girardeau Cnty., 88 F.3d 647 , 650-51 (8th Cir. 1996) (citing Thompson-El v. Jones, 876 F.2d 66, 67 (8th Cir. 1989); Chesnut v. St.
discussed Cited as authority (rule) Williams v. Insomnia Cookies, LLC
E.D. Mo. · 2024 · confidence medium
Unless there is a good reason for denial, “such as undue delay, bad faith, or dilatory motive, repeated failure to cure deficiencies by amendments previously allowed, undue prejudice to the non-moving party, or futility of the amendment, leave to amend should be granted.” Thompson-El v. Jones, 876 F.2d 66, 67 (8th Cir. 1989) (citing Foman v. Davis, 371 U.S. 178, 182 , (1962)).
discussed Cited as authority (rule) NDN Collective v. Retsel Corporation
D.S.D. · 2024 · confidence medium
As the Eighth Circuit has explained, “The classic ‘good reasons' for rejecting an amendment are: ‘undue delay, bad faith or dilatory motive, repeated failure to cure deficiencies by amendments previously allowed, undue prejudice to the non-moving party, or futility of amendment....’” Popp Telcom v. American Sharecom, Inc., 210 F.3d 928, 943 (8th Cir 2000) (quoting 7) hompson-El v. Jones, 876 F.2d 66, 67 (8th Cir.1989) (citing Foman v. Davis, 371 U.S. 178, 182 (1962)).
discussed Cited as authority (rule) Bell v. City of Bourbon, Missouri
E.D. Mo. · 2024 · confidence medium
Unless there is a good reason for denial, “such as undue delay, bad faith, or dilatory motive, repeated failure to cure deficiencies by amendments previously allowed, undue prejudice to the non-moving party, or futility of the amendment, leave to amend should be granted.” Thompson–El v. Jones, 876 F.2d 66, 67 (8th Cir. 1989) (citing Foman v. Davis, 371 U.S. 178, 182 , (1962)).
discussed Cited as authority (rule) Midwest Petroleum Company v. St Louis County
E.D. Mo. · 2024 · confidence medium
Unless there is a good reason for denial, “such as undue delay, bad faith, or dilatory motive, repeated failure to cure deficiencies by amendments previously allowed, undue prejudice to the non-moving party, or futility of the amendment, leave to amend should be granted.” Thompson–El v. Jones, 876 F.2d 66, 67 (8th Cir. 1989) (citing Foman v. Davis, 371 U.S. 178, 182 , (1962)).
discussed Cited as authority (rule) Great American Insurance Company v. Mosher
D.S.D. · 2024 · confidence medium
As the Eighth Circuit has advised, “The classic ‘good reasons' for rejecting an amendment are: ‘undue delay, bad faith or dilatory motive, repeated failure to cure deficiencies by amendments previously allowed, undue prejudice to the non- moving party, or futility of amendment....’” Popp Telcom v. American Sharecom, Inc., 210 F.3d 928, 943 (8th Cir 2000) (quoting Thompson—El v. Jones, 876 F.2d 66, 67 (8th Cir.1989) citing Foman v. Davis, 371 U.S. 178, 182 (1962)).
discussed Cited as authority (rule) Great American Insurance Company v. Mosher
D.S.D. · 2024 · confidence medium
As the Eighth Circuit has advised, “The classic ‘good reasons' for rejecting an amendment are: ‘undue delay, bad faith or dilatory motive, repeated failure to cure deficiencies by amendments previously allowed, undue prejudice to the non- moving party, or futility of amendment....’” Popp Telcom v. American Sharecom, Inc., 210 F.3d 928, 943 (8th Cir 2000) (quoting Thompson—El v. Jones, 876 F.2d 66, 67 (8th Cir.1989) citing Foman v. Davis, 371 U.S. 178, 182 (1962)).
cited Cited as authority (rule) NDN Collective v. Retsel Corporation
D.S.D. · 2024 · confidence medium
American Sharecom, Inc., 210 F.3d 928, 943 (8th Cir 2000) (quoting Thompson—El v. Jones, 876 F.2d 66, 67 (8th Cir.1989) (citing Foman v. Davis, 371 U.S. 178, 182 (1962)).
cited Cited as authority (rule) Kutz v. NGI Capital, Inc.
D. Minnesota · 2023 · confidence medium
Louis Cty., 656 F.2d 343, 349 (8th Cir. 1981); Thompson-El v. Jones, 876 F.2d 66, 67 (8th Cir. 1989)).
discussed Cited as authority (rule) Haukaas v. Liberty Mutual Insurance Company (2×) also: Cited "see"
D.S.D. · 2023 · confidence medium
Thompson-El v. Jones, 876 F.2d 66, 67 (8th Cir. 1989).
discussed Cited as authority (rule) Cigna Corporation v. Bricker
E.D. Mo. · 2023 · confidence medium
Unless there is a good reason for denial, “such as undue delay, bad faith, or dilatory motive, repeated failure to cure deficiencies by amendments previously allowed, undue prejudice to the non-moving party, or futility of the amendment, leave to amend should be granted.” Thompson– El v. Jones, 876 F.2d 66, 67 (8th Cir. 1989) (citing Foman v. Davis, 371 U.S. 178, 182 , (1962)).
discussed Cited as authority (rule) Zoss v. Protsch
D.S.D. · 2023 · confidence medium
As the Eighth Circuit has explained, “The classic ‘good reasons' for rejecting an amendment are: ‘undue delay, bad faith or dilatory motive, repeated failure to cure deficiencies by amendments previously allowed, undue prejudice to the non-moving party, or futility of amendment....’” Popp Telcom v. American Sharecom, Inc., 210 F.3d 928, 943 (8th Cir 2000) (quoting Thompson—El v. Jones, 876 F.2d 66, 67 (8th Cir.1989) (citing Foman v. Davis, 371 U.S. 178, 182 (1962)).
discussed Cited as authority (rule) Yohannes v. Minnesota IT Services
D. Minnesota · 2022 · confidence medium
The Eighth Circuit has held that although amendment of a pleading “should be allowed liberally to ensure that a case is decided on its merits . . . there is no absolute right to amend.” Ferguson v. Cape Girardeau Cty., 88 F.3d 647 , 650-51 (8th Cir. 1996) (citing Thompson-El v. Jones, 876 F.2d 66, 67 (8th Cir. 1989); Chesnut v. St.
discussed Cited as authority (rule) Green v. Gunderson
W.D. Ark. · 2022 · confidence medium
McLaurin v. Prater, 30 F.3d 982, 985 (8th Cir. 1994). “[A]bsent a good reason for denial—such as . . . futility of amendment—leave to amend should be granted.” Thompson-El v. Jones, 876 F.2d 66, 67 (8th Cir. 1989).
cited Cited as authority (rule) Hayes v. Henderson
W.D. Ark. · 2022 · confidence medium
Thompson-El v. Jones, 876 F.2d 66, 67 (8th Cir. 1989).
discussed Cited as authority (rule) Andrews v. Fairview Health Services
D. Minnesota · 2022 · confidence medium
(Dkt. 1-1 ¶¶ 84, 89.) As such, the Court finds that punitive damages as to these claims has already been pled in this action and no further motion to amend is required. pleading “should be allowed liberally to ensure that a case is decided on its merits . . . there is no absolute right to amend.” Ferguson v. Cape Girardeau Cty., 88 F.3d 647 , 650-51 (8th Cir. 1996) (citing Thompson-El v. Jones, 876 F.2d 66, 67 (8th Cir. 1989); Chesnut v. St.
cited Cited as authority (rule) State of North Dakota v. Susan Bala
8th Cir. BAP · 2022 · confidence medium
D.S.C. 2019); Thompson-El v. Jones, 876 F.2d 66, 69 (8th Cir. 1989).
discussed Cited as authority (rule) Cullars-Doty v. City of St. Paul
D. Minnesota · 2021 · confidence medium
The Eighth Circuit has held that “[a]lthough amendment of a complaint should be allowed liberally to ensure that a case is decided on its merits . . . there is no absolute right to amend.” Ferguson v. Cape Girardeau Cty., 88 F.3d 647 , 650-51 (8th Cir. 1996) (citing Thompson-El v. Jones, 876 F.2d 66, 67 (8th Cir. 1989); Chesnut v. St.
discussed Cited as authority (rule) Taylor v. Kansas City Southern Railway Company
W.D. Ark. · 2021 · confidence medium
This is a liberal standard, as courts “should freely give leave when justice so requires.” Doe v. Cassel, 403 F.3d 986, 990 (8th Cir. 2005). “[A]bsent a good reason for denial—such as undue delay, bad faith or dilatory motive, repeated failure to cure deficiencies by amendments previously allowed, undue prejudice to the non-moving party, or futility of amendment—leave to amend should be granted.” Thompson-El v. Jones, 876 F.2d 66, 67 (8th Cir. 1989).
discussed Cited as authority (rule) Cross v. State Farm Mutual Automobile Insurance Company
W.D. Ark. · 2021 · confidence medium
McLaurin v. Prater, 30 F.3d 982, 985 (8th Cir. 1994). “[A]bsent a good reason for denial—such as undue delay, bad faith or dilatory motive, repeated failure to cure deficiencies by amendments previously allowed, undue prejudice to the non-moving party, or futility of amendment—leave to amend should be granted.” Thompson-El v. Jones, 876 F.2d 66, 67 (8th Cir. 1989).
discussed Cited as authority (rule) Spottswood v. Washington County
D. Minnesota · 2021 · confidence medium
The Eighth Circuit has held that although amendment of a pleading “should be allowed liberally to ensure that a case is decided on its merits . . . there is no absolute right to amend.” Ferguson v. Cape Girardeau Cnty., 88 F.3d 647 , 650-51 (8th Cir. 1996) (citing Thompson-El v. Jones, 876 F.2d 66, 67 (8th Cir. 1989); Chesnut v. St.
discussed Cited as authority (rule) Jones-El v. Godert
E.D. Mo. · 2021 · confidence medium
Co., 160 F.3d 452, 454 (8th Cir. 1998) (holding risk of prejudice resulting from late pleading amendments which imposed additional discovery requirements justified denial of motion to amend); Thompson-El v. Jones, 876 F.2d 66, 67-69 (8th Cir. 1989) (no abuse of discretion in denying motion to amend where grant most likely would have necessitated additional discovery and further delay).
discussed Cited as authority (rule) Wagner v. FranChoice, Inc.
D. Minnesota · 2020 · confidence medium
The Eighth Circuit has held that “[a]lthough amendment of a complaint should be allowed liberally to ensure that a case is decided on its merits . . . there is no absolute right to amend.” Ferguson v. Cape Girardeau Cty., 88 F.3d 647 , 650-51 (8th Cir. 1996) (citing Thompson-El v. Jones, 876 F.2d 66, 67 (8th Cir. 1989); Chesnut v. St.
discussed Cited as authority (rule) The Orange Rabbit, Inc. v. Franchoice, Inc.
D. Minnesota · 2020 · confidence medium
The Eighth Circuit has held that “[a]lthough amendment of a complaint should be allowed liberally to ensure that a case is decided on its merits . . . there is no absolute right to amend.” Ferguson v. Cape Girardeau Cty., 88 F.3d 647 , 650-51 (8th Cir. 1996) (citing Thompson-El v. Jones, 876 F.2d 66, 67 (8th Cir. 1989); Chesnut v. St.
discussed Cited as authority (rule) Johnson v. Franchoice, Inc.
D. Minnesota · 2020 · confidence medium
The Eighth Circuit has held that “[a]lthough amendment of a complaint should be allowed liberally to ensure that a case is decided on its merits . . . there is no absolute right to amend.” Ferguson v. Cape Girardeau Cty., 88 F.3d 647 , 650-51 (8th Cir. 1996) (citing Thompson-El v. Jones, 876 F.2d 66, 67 (8th Cir. 1989); Chesnut v. St.
cited Cited as authority (rule) Dean v. Johnston
D. Minnesota · 2020 · confidence medium
Thompson–El v. Jones, 876 F.2d 66, 67 (8th Cir. 1989).
discussed Cited as authority (rule) Akman v. Bayer Healthcare Pharmaceuticals, Inc. (2×) also: Cited "see"
D. Minnesota · 2020 · confidence medium
Thompson–El v. Jones, 876 F.2d 66, 67 (8th Cir. 1989).
discussed Cited as authority (rule) Huskey v. Colgate-Palmolive Company
E.D. Mo. · 2020 · confidence medium
Perkins v. Spivey, 911 F.2d 22, 34-35 (8th Cir.1990) (no abuse of discretion where movant waited eighteen months after filing before seeking to amend and extensive discovery already conducted); Thompson-El v. Jones, 876 F.2d 66, 67-68 (8th Cir.1989) (no abuse of discretion in denying motion amend , -. since eighteen months had passed since filing of complaint, motion was made two weeks before trial and discovery cutoff had passed).
discussed Cited as authority (rule) Garrity v. Klimisch
D.S.D. · 2020 · confidence medium
In the absence of such an apparent or declared reason—such as undue delay, bad faith or dilatory motive on the part of the movant, repeated failure to cure deficiencies by amendments previously allowed, undue prejudice to the opposing party by virtue of allowance of the amendment, futility of the amendment, etc.—the leave sought should, as the rules require, be “freely given.” Forman v. Davis, 371 U.S. 178, 182 (1962); Thompson-El v. Jones, 876 F.2d 66, 67 (8th Cir. 1989).
discussed Cited as authority (rule) PHT Holding I LLC v. ReliaStar Life Insurance Company
D. Minnesota · 2020 · confidence medium
The Eighth Circuit has held that “[a]lthough amendment of a complaint should be allowed liberally to ensure that a case is decided on its merits . . . there is no absolute right to amend.” Ferguson v. Cape Girardeau Cty., 88 F.3d 647 , 650-51 (8th Cir. 1996) (citing Thompson-El v. Jones, 876 F.2d 66, 67 (8th Cir. 1989); Chesnut v. St.
discussed Cited as authority (rule) Lessert v. BNSF Railway Company
D.S.D. · 2020 · confidence medium
However, the granting of such a motion is left to the “discretion of the district court.” Russ v. Ratliff, 578 F.2d 221, 224 (8th Cir. 1978) (internal citations omitted). “[A]bsent a good reason for denial—undue delay, bad faith or dilatory motive, repeated failure to cure deficiencies by amendments previously allowed, undue prejudice to the non-moving party, or futility of amendment—leave to amend should be granted.” Thompson–El v. Jones, 876 F.2d 66, 67 (8th Cir. 1989).
discussed Cited as authority (rule) Foster v. Litman
D. Minnesota · 2020 · confidence medium
The Eighth Circuit has held that “[a]lthough amendment of a complaint should be allowed liberally to ensure that a case is decided on its merits . . . there is no absolute right to amend.” Ferguson v. Cape Girardeau Cty., 88 F.3d 647 , 650-51 (8th Cir. 1996) (citing Thompson-El v. Jones, 876 F.2d 66, 67 (8th Cir. 1989); Chesnut v. St.
discussed Cited as authority (rule) Hasko v. Franchoice, Inc.
D. Minnesota · 2020 · confidence medium
The Eighth Circuit has held that although amendment of a pleading “should be allowed liberally to ensure that a case is decided on its merits . . . there is no absolute right to amend.” Ferguson v. Cape Girardeau Cty., 88 F.3d 647 , 650-51 (8th Cir. 1996) (citing Thompson-El v. Jones, 876 F.2d 66, 67 (8th Cir. 1989); Chesnut v. St.
discussed Cited as authority (rule) Hamilton v. Franchoice, Inc.
D. Minnesota · 2020 · confidence medium
The Eighth Circuit has held that although amendment of a pleading “should be allowed liberally to ensure that a case is decided on its merits . . . there is no absolute right to amend.” Ferguson v. Cape Girardeau Cty., 88 F.3d 647 , 650-51 (8th Cir. 1996) (citing Thompson-El v. Jones, 876 F.2d 66, 67 (8th Cir. 1989); Chesnut v. St.
discussed Cited as authority (rule) Johnson v. Franchoice, Inc.
D. Minnesota · 2020 · confidence medium
The Eighth Circuit has held that although amendment of a pleading “should be allowed liberally to ensure that a case is decided on its merits . . . there is no absolute right to amend.” Ferguson v. Cape Girardeau Cty., 88 F.3d 647 , 650-51 (8th Cir. 1996) (citing Thompson-El v. Jones, 876 F.2d 66, 67 (8th Cir. 1989); Chesnut v. St.
discussed Cited as authority (rule) Golden Polar Bear, LLC v. Franchoice, Inc.
D. Minnesota · 2020 · confidence medium
The Eighth Circuit has held that although amendment of a pleading “should be allowed liberally to ensure that a case is decided on its merits . . . there is no absolute right to amend.” Ferguson v. Cape Girardeau Cty., 88 F.3d 647 , 650-51 (8th Cir. 1996) (citing Thompson-El v. Jones, 876 F.2d 66, 67 (8th Cir. 1989); Chesnut v. St.
Retrieving the full opinion text from the archive…
Sean THOMPSON-EL, Appellant,
v.
Jimmy JONES, Superintendent; Dick Moore, Theresa Thornburg, Appellees
88-1968.
Court of Appeals for the Eighth Circuit.
Jun 1, 1989.
876 F.2d 66
1989 U.S. App. LEXIS 7588
1989 WL 56597
Jeffrey S. Kerr, St. Louis, Mo., for appellant., Paul Rauschenbach, Asst. Atty. Gen., Jefferson City, Mo., for appellees.
Gibson, Bowman, Heaney.
Cited by 143 opinions  |  Published
BOWMAN, Circuit Judge.

Sean Thompson-El appeals following a grant of summary judgment in favor of defendants-appellees. Thompson-El claims that the United States Magistrate [1] erred prior to granting summary judgment by denying him leave to file a second amended complaint. We affirm.

I.

This ease was initiated in October 1986 when Thompson-El filed a pro se complaint under 42 U.S.C. § 1983 (1982) against officials of the Missouri Training Center for Men (MTCM) in Moberly, Missouri. The next month Thompson-El amended his complaint, adding both defendants and claims, and the claims in his original complaint subsequently were dismissed. His amended complaint alleged inter alia that individuals associated with MTCM had violated his First, Fourth, Fifth, Eighth, and Fourteenth Amendment rights. Specifically, Thompson-El claimed that he was being held in administrative segregation without having received “a report of definite misconduct, without adequate access to the courts and without a meaningful ... investigation” into the incident that precipitated his confinement in administrative segregation. Appendix of Appellant (App.) at 14. He demanded that the investigation be concluded or that he be returned to the general prison population.

On December 29, 1987, Jeffrey S. Kerr was appointed as Thompson-El’s counsel. Kerr entered his appearance on Thompson-[*67] El’s behalf February 4, 1988. Around February 22 the trial court entered discovery deadlines and notified the parties that trial had been set for May 23,1988. Thompson-El moved for a continuance March 3, 1988, stating that “a prior scheduling conflict rendered] [his] counsel unavailable for trial” on the scheduled date and requesting that the trial be re-scheduled for “a later time to be determined by the Court.” App. at 34. The continuance was granted and the trial re-scheduled for May 25, 1988.

Although Thompson-El’s counsel was appointed in December 1987, he did not meet with Thompson-El to discuss the case until May 3, 1988. Prior to that, discussions between counsel and Thompson-El had been limited to brief telephone calls. On May 10, two weeks before the trial was to start, Thompson-El sought leave to file a second amended complaint, in which he named four more defendants, presented at least one new claim (that the Adjustment Board’s December 18, 1986 proceedings finding Thompson-El guilty of involvement in an assault were unconstitutional), and added demands for actual and punitive damages. The motion for leave to amend was denied. Thereafter, defendants’ motion for summary judgment, which argued inter alia that Thompson-El’s claims were moot, was granted. The trial court agreed that the claims were moot, stating that “[b]ecause the investigation ... has been completed and the plaintiff has been transferred from MTCM to another institution, his claim for injunctive relief is moot,” and “there is nothing in the complaint from which a request for monetary relief may be inferred.” App. at 68. Judgment in favor of defendants was entered, and Thompson-El appeals.

II.

Federal Rule of Civil Procedure 15(a) governs a party’s right to amend its pleadings. The Rule provides in pertinent part that leave of court to amend a complaint “shall be freely given when justice so requires.” [2] As explained by the Supreme Court, absent a good reason for denial— such as undue delay, bad faith or dilatory motive, repeated failure to cure deficiencies by amendments previously allowed, undue prejudice to the non-moving party, or futility of amendment — leave to amend should be granted. Foman v. Davis, 371 U.S. 178, 182, 83 S.Ct. 227, 230, 9 L.Ed.2d 222 (1962). Amendment of pleadings is to be liberally allowed, but the trial court’s decision whether to allow amendment will be reviewed only for an abuse of discretion. See Zenith Radio Corp. v. Hazeltine Research, Inc., 401 U.S. 321, 330, 91 S.Ct. 795, 802, 28 L.Ed.2d 77 (1971). Having considered the circumstances surrounding the denial of Thompson-El’s motion to amend, we find that there was good reason to deny the motion, and therefore cannot say that the trial court abused its discretion. [3]

The policy favoring liberal allowance of amendment does not mean that the right to amend is absolute. When a considerable amount of time has passed since the filing of a complaint and the motion to amend is made on the eve of trial and will cause prejudice and further delay, courts require the movant to provide some valid reason for the belatedness of the motion.[*68] See Stepanischen v. Merchants Despatch Transp. Corp., 722 F.2d 922, 933 (1st Cir.1983); see also Mills v. Des Arc Convalescent Home, 872 F.2d 823, 825-26 (8th Cir. April 19, 1989). Here the motion to amend was filed after the case had been pending for approximately eighteen months and just two weeks before the trial was to start. It was made almost six weeks after the date originally set for completion of discovery and two weeks after the deadline for summary judgment motions. Furthermore, grant of the motion most likely would have necessitated additional discovery and further delay. Indeed, Thompson-El moved to file discovery out of time and for a continuance the day before he filed the motion to amend, and in the motion for a continuance he indicated that to allow him adequate time to prepare for trial on the matters raised in his second amended complaint the court should set trial no earlier than August 1, 1988.

Thompson-El argues, of course, that the belatedness of his motion to amend should have been excused. He contends that it was “impossible for ... counsel to discover the need” for a second amended complaint until he and counsel met and received certain discovery materials. Brief for Appellant at 13-14. As noted above, however, counsel was appointed for Thompson-El in December 1987. The discovery materials were not requested until the first week of the following April and counsel and Thompson-El did not meet until the following May. Thompson-El provides no explanation for not requesting the discovery materials earlier, except to say the request was not late under the discovery schedule, and the failure to meet until May 3 he attributes to “counsel’s scheduling conflicts and [his own] incarceration at [the Missouri State Penitentiary (MSP)], some four (4) hours away, one way, from counsel’s offices by automobile.” [4] Brief for Appellant at 13. Suffice it to say that we find these explanations unimpressive.

Thompson-El also makes much of the fact that the complaint he was denied leave to amend, i.e., his first amended complaint, was filed pro se. He argues that the “rules favoring liberality in amending pleadings are particularly crucial” here because the pro se litigant is more prone to make errors than is the litigant represented by counsel. Brief for Appellant at 12-13. In the circumstances of this case, however, we think that point provides little excuse. Because Thompson-El had been acting pro se, counsel should have realized that deficiencies in the pleadings were likely and, once he had an opportunity to become familiar with this case, should have filed the motion to amend promptly.

Defendants contend that Thompson-El’s attorney simply did not want to go to trial in late May because of certain social engagements and his late-date maneuvering was an attempt to avoid having to do so. The record provides some support for this view. For example, in the May 9 motion for continuance (filed the day before the motion to amend), Thompson-El explained that the May 9 and March 3 continuances both were made because counsel planned to be “absent for ten (10) of the last fourteen (14) days immediately preceding the trial date” in order to participate in two out-of-town weddings. App. at 53-54. [5] Defendants argue in essence that, rather than seeking leave to file a second amended complaint in order to press legitimate claims, Thompson-El filed the motion in order to delay trial until a time more convenient for counsel. If a motion to amend is filed for dilatory purposes, a court has good reason to deny the motion. See Foman, 371 U.S. at 182, 83 S.Ct. at 230. On[*69] the facts of this case, we believe the trial court could well have concluded that the motion to amend was prompted by such motives.

Parties m litigation, as well as the courts, are entitled to expect opposing parties to prepare their cases in timely fashion. “Trial settings are to be taken seriously and discovery must be conducted [in such a way that the parties are prepared] for trial on the date scheduled....” Mercantile Trust Co. Nat’l Ass’n v. Inland Marine Prods., 542 F.2d 1010, 1013 (8th Cir.1976). In this case, it is clear that Thompson-El’s pretrial preparation was approached with a marked lack of diligence: Thompson-El and counsel did not even meet until two weeks after defendants filed their motion for summary judgment. More importantly, the addition in the second amended complaint of four new defendants, a distinct claim, and demands for actual and punitive damages would have changed this case quite substantially. The additional burdens of discovery and delay the amendment would have placed on defendants we are unwilling to characterize as insignificant prejudice, especially in light of Thompson-El’s inability to provide a valid excuse for his failure to act earlier. See Hayes v. New England Millwork Distribs., Inc., 602 F.2d 15, 20 (1st Cir.1979); see also Mills, 872 F.2d at 825-26; Stepanischen, 722 F.2d at 933. In the circumstances of this case, the trial court did not abuse its discretion in denying Thompson-El leave to file his second amended complaint. [6]

AFFIRMED.

1

. The Honorable Carol E. Jackson, United States Magistrate for the Eastern District of Missouri, before whom the parties consented to trial. See 28 U.S.C. § 636(c) (1982).

2

. The full text of Rule 15(a) provides:

(a) Amendments. A party may amend the party’s pleading once as a matter of course at any time before a responsive pleading is served or, if the pleading is one to which no responsive pleading is permitted and the action has not been placed upon the trial calendar, the party may so amend it at any time within 20 days after it is served. Otherwise a party may amend the party’s pleading only by leave of court or by written consent of the adverse party; and leave shall be freely given when justice so requires. A party shall plead in response to an amended pleading within the time remaining for response to the original pleading or within 10 days after service of the amended pleading, whichever period may be the longer, unless the court otherwise orders.
3

. The trial court’s failure to articulate its reasons for denying the motion, contrary to what Thompson-El suggests, is not per se an abuse of discretion. See, e.g., Rhodes v. Amarillo Hosp. Dist., 654 F.2d 1148, 1153-54 (5th Cir.1981). We reiterate, however, that as a matter of good practice a trial court should provide reasons for the denial of a motion to amend. See Hannah v. City of Overland, 795 F.2d 1385, 1392 (8th Cir.1986).

4

. Counsel’s offices are in St. Louis, Missouri, and MSP is located approximately 130 miles away in Jefferson City, Missouri. Thompson-El was transferred from MTCM to MSP after the Adjustment Board found him guilty of involvement in an assault on a fellow MTCM inmate.

5

. Had the March 3 motion for continuance been more artfully drafted, Thompson-El might then have received a continuance more to his liking. As we noted earlier, however, Thompson-El simply stated in that motion that counsel would be unavailable May 23 and requested only that the trial not start that day but at “a later time to be determined by the Court.” App. at 34. Apparently, no clarification of counsel’s schedule or other request for a delayed trial date was presented to the trial court until May 9.

6

. Although the above discussion disposes of the issue before us, we add this brief comment. As we noted, this case stems from Thompson-El's confinement in administrative segregation. Thompson-El was placed in administrative segregation July 20, 1986 pending the outcome of an investigation into his involvement in a July 19 assault on a fellow MTCM inmate. The investigation lasted into the following December, and Thompson-El alleged in his first amended complaint that the investigation was a mere pretext for keeping him in administrative segregation. Because the trial court correctly dismissed the case as moot, it did not address the substance of Thompson-El’s claims. Absent mootness, we believe Thompson-El's claims might have had some merit, for our review of the record discloses little or no investigative activity for much of the period between July and December. We, of course, do not decide here whether the investigation was unduly delayed or prolonged to provide a pretext for keeping Thompson-El in administrative segregation. We do point out, however, that when an inmate has acquired a constitutionally protected interest in remaining in the general prison population, the fact that an investigation is characterized as “ongoing" will not automatically justify keeping the inmate in administrative segregation. See Hewitt v. Helms, 459 U.S. 460, 477 n. 9, 103 S.Ct. 864, 874 n. 9, 74 L.Ed.2d 675 (1983). Moreover, we think it fair to say that "[t]he lengthier the period of administrative detention, the more likely it may be that [the] investigation’ is merely a pretext.” Id. at 493, 103 S.Ct. 883 (Stevens, J., dissenting). As protection against deprivation of their rights, inmates so confined are entitled to periodic review of their administrative segregation status. Id. at 477 n. 9, 103 S.Ct. at 874 n. 9.