Phyllis G. Kyle v. Campbell Soup Company

Campbell Soup Company appeals from the district court’s order granting Phyllis Kyle an enlargement of time to file her motion for attorney’s fees and the subsequent award of $50,446.75 in fees. We reverse the order granting the enlargement of time and the award of attorney’s fees because the district court abused its discretion by finding that a mistake of law constitutes excusable neglect under Rule 6(b) of the Federal Rules of Civil Procedure.

I.

Factual and Procedural Background

On November 16, 1987, Phyllis Kyle filed suit against Campbell Soup Company, her employer, alleging sex discrimination in violation of Title YII and the California Fair Employment and Housing Act. She complained that she was assigned regular mechanic work and menial tasks instead of overhaul work that was performed by the man who previously held her position. Kyle asserted that she suffered “extreme humiliation, mental anguish, emotional distress and physical injury,” amounting to one million dollars in damage. She also sought three million dollars in punitive damages and an injunction enjoining Campbell Soup from discriminating on the basis of sex.

Following a bench trial, the district court found…