Delivering opportunities for growth

Join Clark Hill’s Healthcare industry attorneys for a complimentary dinner and program focusing on the latest challenges and top trends in the healthcare industry. There will be plenty of time to catch up with old friends and make new connections before and after the presentations.

On Tuesday Dec. 2, 2025, USCIS released a policy memorandum titled “Hold and Review of all Pending Asylum Applications and all USCIS Benefit Applications Filed by Aliens from High-Risk Countries.” Under this memorandum and effective immediately, USCIS is suspending a range of pending immigration benefits applications, re-reviewing certain approved applications, and suspending the processing of all applications for asylum and withholding of removal for any applicant.

Every litigation attorney knows Federal Rule of Civil Procedure 15(a) requires courts to “freely give leave” to amend pleadings “when justice so requires.” It’s drilled into us in law school and repeated in countless court opinions. But here’s what catches even experienced practitioners off guard: Rule 15(a)’s liberal amendment standard doesn’t automatically apply when you’ve missed the amendment deadline in the court’s scheduling order. Two recent federal cases—one from Texas, one from California—perfectly illustrate this critical trap and why understanding Rule 16(b)(4)’s “good cause” standard can make or break your case.