U.S. Supreme Court Rules on "Relation Back" of Amended Pleadings Under Rule 15(c) of the Federal Rules of Civil Procedure
On June 7, 2010, the United States Supreme Court issued its decision in Krupski v. Costa Crociere S.P.A., in which it considered the issue of when an amended pleading that changes a party or a party's name will "relate back" to the date of a timely filed original pleading and will thus be considered timely despite being filed outside the applicable statute of limitations. In an opinion written by Justice Sotomayor, the Court held that relation back under the applicable Federal Rule of Civil Procedure depends on what the party to be added knew or should have known, not on the amending party's knowledge or its timeliness in seeking to amend the pleading.
In Krupski, the petitioner, Mrs. Krupski, was injured while on board a cruise ship. Mrs. Krupski's passenger ticket, the sole contract between each passenger and the carrier, required that notice of claims be submitted to the "carrier" and that all lawsuits be brought within one (1) year after the date of injury. The ticket further identified the carrier as "Costa Crociere S.p.A." "Costa Cruise Lines N.V." was identified as the issuer of the ticket and this name was displayed on the front of the ticket. The petitioner's counsel timely notified Costa Cruise Lines of Mrs. Krupski's claims, and when an amicable settlement could not be reached, Mrs. Krupski timely commenced a negligence action against Costa Cruise Lines. Costa Cruise Lines repeatedly asserted that the proper defendant was actually the carrier, Costa Crociere S.p.A., and moved for summary judgment. The Federal District Court for the Southern District of Florida denied Costa Cruise Lines' motion for summary judgment and permitted Mrs. Krupski to amend the complaint to name Costa Crociere S.p.A. as defendant. Notwithstanding, upon Costa Crociere S.p.A.'s motion, the District Court dismissed Mrs. Krupski's amended complaint, ruling that it was untimely. In so holding, the District Court looked to Rule 15(c) of the Federal Rules of Civil Procedure, which governs when an amended pleading will "relate back" to the timely filed original pleading. The Court concluded that the petitioner had not made a mistake concerning the identity of the proper party, but rather had intentionally chosen to sue one party rather than the other. The Eleventh Circuit Court of Appeals affirmed the District Court's decision, and the Supreme Court granted certiorari to resolve tension amongst the Circuit Courts concerning the breadth of Rule 15(c).
In its opinion, the Supreme Court looked to the text of Rule 15(c)(1)(C), which provides that an amendment which "changes the party or the naming of the party against whom a claim is asserted" will "relate back" to the date of the original pleadings if, inter alia, "within the period . . . for serving the summons and complaint, the party to be brought in by amendment (i) received such notice of the action that it will not be prejudiced in defending on the merits; and (ii) knew or should have known that the action would have been brought against it, but for a mistake concerning the proper party's identity." The Court found that the Court of Appeals had incorrectly focused on whether Mrs. Krupski, the claimant, knew or should have known of the proper party's identity. The Court ruled that the proper inquiry under Rule 15(c)(1)(C)(ii) is whether the party sought to be named in the amended pleading (in this case, Costa Crociere S.p.A.) knew or should have known that, absent some mistake, the action would have been brought against him. The Court similarly rejected the Eleventh Circuit's ruling that Mrs. Krupski had unduly delayed in seeking to file (and later filing) an amended complaint against Costa Crociere S.p.A, holding that "[Rule 15(c)] does not leave the decision whether to grant relation back to the district court's equitable discretion" once the Rule's requirements are satisfied.
In reversing the Eleventh Circuit's decision, the Court concluded that the complaint made clear that Mrs. Krupski meant to sue the company that "owned, operated, managed, supervised and controlled" the ship on which she was injured. Although she mistakenly indicated that Costa Cruise Lines performed these roles, Costa Crociere should have known that it was not named as a defendant in the complaint only because of Mrs. Krupski's mistake concerning the proper party's identity. The Eleventh Circuit's judgment was reversed and the Supreme Court remanded the case for further proceedings consistent with its opinion.
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