McManis

The San Diego Postal Credit Union (Credit Union) loaned Lourdes G. McManis money to purchase an automobile. At the same time, Credit Union sold Lourdes a disability credit insurance policy issued by Life Investors Insurance Company (Life Investors). After making her loan and insurance payments for three years, McManis became disabled and was unable to continue making the payments on her loan. McManis filed a disability claim with Life Investors and, while the claim was pending, Credit Union repossessed her vehicle. As a result of the repossession, McManis allegedly suffered emotional distress and property damage.

McManis sued Credit Union and Life Investors. Thereafter, Life Investors paid McManis’s disability claim in full and Credit Union returned her vehicle. McManis later amended her complaint to add the company that repossessed the vehicle, San Diego Auto Recovery, Inc. (Auto Recovery), as a Doe defendant. Defendants moved for summary judgment. McManis opposed the summary judgment and moved to amend the complaint. After permitting McManis to file supplemental papers, the court granted summary judgment and denied the motion to amend.

McManis appeals. In the…