CPLR 3025(b)

Practice point: Although leave to amend a pleading is freely granted, it should not be granted simply because it is requested and without appropriate substantiation.

Case: Hoppe v. Board of Directors of the 51-78 Owners Corp., NY Slip Op 02771 (1st Dept. 2008)

Facts: One of the cooperative's shareholders sought to amend the complaint to include a breach of fiduciary duty claim against various past and present members of the cooperative corporation and its board, but did not allege any independent tortious conduct by any individual director.