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In Archstone Multifamily Series I Trust v. Niles Bolton Assoc., No. 09-1453, the Fourth Circuit faced a challenge to the district court's grant of summary judgment in favor of defendant and denial of plaintiff's motion to amend its complaint to include a claim for contribution in a suit for express and implied indemnity, breach of contract and professional negligence, arising from an underlying suit against the parties for FHA and ADA violations in the construction of multi-family housing projects throughout the U.S.
In affirming the district court's grant of summary judgment, the court held that the de facto indemnification state-law claims are preempted under federal law and the district court did not abuse its discretion in determining that the proposed amendment would be unduly prejudicial to defendant.
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