Original sentence: Davis moved to dismiss the case, arguing that an oral promise not to execute a will was within the statute of frauds and thus unenforceable
Edited sentence: "  In the Court's view, this meant that the standard for granting leave to amend was quite liberal:  only in very limited circumstances would a denial of leave to amend be justified.Absent such special circumstances, it would be an abuse of discretion for a court to deny leave to amend.Accordingly, the First Circuit had no need to consider Foman's quantum meruit argument.Davis moved to dismiss the case, arguing that, under Massachusetts law, an oral promise not to execute a will was within the statute of frauds and thus unenforceable.Harlan agreed that the First Circuit should have considered the merits of Foman's case, but he believed the question of whether Foman should have been allowed to amend her complaint was best left to the lower courts.Instead, the First Circuit should have considered the merits at the same time as the motions to vacate and amend.It has been recognized by both other courts and secondary sources as a leading decision on the interpretation of Rule 15(a).It overturned the district court, ruling that under Massachusetts law, an oral promise not to execute a will was not rendered unenforceable by the statute of frauds.Justice Goldberg, writing for the Court, began by holding that the First Circuit was wrong to fird that it could not consider the merits of the case because Foman moved to vacate the judgment after filing her initial appeal.On remand, the First Circuit considered the merits of Foman's case, as the Supreme Court had directed.Specifically, the Court found that undue delay, bad faith or dilatory motive on the part of the movant, repeated failure to cure deficiencies by previous amendment, prejudice to the opposing party, and futility of amendment would support a denial.The Court granted Foman's motion to amend her complaint and remanded the case to the First Circuit for proceedings consistent with its opinion.The Court then turned to the First Circuit's denial of Foman's motion to amend her complaint.The Supreme Court agreed to review the case.The second Justice Harlan, writing for himself and Justice White, issued a two-sentence opinion concurring in part and dissenting in part.Under Rule 15(a), federal courts "should freely give leave [to amend] when justice so requires