concluding that the district court erred in denying relation back where the corporate defendant that plaintiff sought to add under Rule 15(c)(1)(C) was related to named defendant, had "constructive notice" of the original complaint within the Rule 4(m) period, and should have known that it would have been named in the original complaint but for plaintiff's mistake about which corporate entity was the proper defendant
How later courts described this case
- concluding that the district court erred in denying relation back where the corporate defendant that plaintiff sought to add under Rule 15(c)(1)(C) was related to named defendant, had "constructive notice" of the original complaint within the Rule 4(m) period, and should have known that it would have been named in the original complaint but for plaintiff's mistake about which corporate entity was the proper defendant
- explaining that, “[w]hen the original complaint and the plaintiff's conduct compel the conclusion that the failure to name the prospective defendant in the original complaint was the result of a fully informed decision as opposed to a mistake concerning the proper defendant’s identity, the requirements of Rule 15(c)(1)(C)(11) are not met”
- finding relation back when proper and improper defendant were related corporate entities with similar names, proper defendant knew name similarity was confusing for customers, and the complaint “made clear” that the plaintiff intended to sue the proper defendant but for the mistake concerning the proper party’s identity
- reasoning that even if a plaintiff’s mistake is not reasonable, the defendant still could understand that the plaintiff “harbor[s] a misunderstanding about his status or role in the events giving rise to the claim at issue and she may mistakenly choose to sue a different defendant based on that misimpression”
Written by the judges who cited it.
Distinguished
Distinguished by Dunfee v. Finchum, 132 F. Supp. 3d 968 (2015)
Krupski, however, is distinguishable from this case.
The opinion
Justice Scalia,
concurring in part and concurring in the judgment.
I join the Court’s opinion except for its reliance, ante, at 550-551, 554, n. 5, on the Notes of the Advisory Committee as establishing the meaning of Federal Rule of Civil Procedure 15(c)(1)(C). The Advisory Committee’s insights into the proper interpretation of a Rule’s text are useful to the same extent as any scholarly commentary. But the Committee’s intentions have no effect on the Rule’s meaning. Even assuming that we and the Congress that allowed the Rule to take effect read and agreed with those intentions, it is the text of the Rule that controls. Tome v. United States, 513 U. S. 150, 167-168 (1995) (Scalia, J., concurring in part and concurring in judgment).