Federal Rule Of Civil Procedure 15(C) Relation Back Doctrine

42 Florida cases classified under this topic · sorted by citation count · browse and sort

• Sessions v. Rusk State Hosp.
  648 F.2d 1066· 5th Cir.· 1981-06-26 ·cited 67×
  The Eleventh Amendment bars the § 1981 claim against the state hospital, but the amended Title VII claim relates back and is timely; however, the plaintiff failed to prove racial discrimination on the merits.
• Reberta Ingram v. Vijay S. Kumar
  585 F.2d 566· 2d Cir.· 1978-10-19 ·cited 42×
  The court held that an amendment correcting a misnomer relates back to the original filing date if the defendant received notice within the period allowed for service of process, even if that period extends beyond the statute of limitations.
• Bennie Bailey v. N. Ind. Pub. Serv. Co.
  910 F.2d 406· 7th Cir.· 1990-08-09 ·cited 33×
  The jury's verdict and judgment must be vacated because most of the plaintiff's claims are no longer actionable under § 1981 after Patterson v. McLean, and the remaining claims were either time-barred or insufficiently proven. However, Title VII claims remain viable.
• Hunt v. Am. Bank & Tr. Co. OF Baton Rouge
  783 F.2d 1011· 11th Cir.· 1986-03-03 ·cited 33×
  The court held that all claims, including RICO, were time-barred by the applicable statutes of limitations, affirming the district court's dismissal.
• Nw. Acceptance Corp. v. Lynnwood Equip., Inc.
  841 F.2d 918· 9th Cir.· 1988-03-04 ·cited 32×
  The court affirmed the district court's judgment, holding that the security agreement, not the financing statement, defined the extent of the security interest, and that various claims and counterclaims were either without merit, waived, or barred by law.
• Allied Int'l, Inc. v. Int'l Longshoremen's Ass'n, AFL-CIO
  814 F.2d 32· 1st Cir.· 1987-03-23 ·cited 30×
  The court held that an amendment substituting a new plaintiff relates back to the original filing date under Fed.R.Civ.P. 15(c) if the claim arises from the same conduct, there is an identity of interest, and no prejudice results, and that a local union participating in an illega
• Lulu R. Williams v. Army & AIR Force Exch. Serv.
  830 F.2d 27· 3d Cir.· 1987-10-02 ·cited 26×
  A plaintiff cannot amend a complaint to name the correct defendant after the limitations period has passed if the correct defendant did not receive notice within that period, and equitable tolling is unavailable without active misleading by the defendant.
• Villante v. Dep't OF Corr. OF the City OF NEW York
  786 F.2d 516· 2d Cir.· 1986-03-19 ·cited 22×
  The court held that the district court abused its discretion by denying discovery and improperly granting summary judgment on the sexual assault claim, but correctly dismissed the wrongful confinement claim.
• Ricard v. Birch
  529 F.2d 214· 4th Cir.· 1975-12-04 ·cited 22×
  The court held that the statute of limitations was tolled by the Soldiers' and Sailors' Civil Relief Act, preventing dismissal of the wrongful death action.
• Cochrane v. Iowa Beef Processors, Inc.
  596 F.2d 254· 8th Cir.· 1979-01-05 ·cited 19×
  The dissenting judge argues that the panel's decision on venue was unsound and should be reconsidered en banc.
• Ashland v. Ling-Temco-Vought, Inc.
  711 F.2d 1431· 9th Cir.· 1983-07-29 ·cited 18×
  The court held that the amended complaints related back to the original filing date, and that the "forthwith service" requirement of the Suits in Admiralty Act was satisfied by service of the amended complaints. The court remanded for reconsideration of the district court's findi
• Watts v. Pinckney
  752 F.2d 406· 9th Cir.· 1985-01-22 ·cited 15×
• Hill v. Shelander
  924 F.2d 1370· 7th Cir.· 1991-02-12 ·cited 13×
  The dissenting judge argues that the majority erred in allowing an amendment to change the capacity of the defendant from official to individual to relate back to the original filing date, as it did not involve a mistake in identity and prejudiced the defendant.
• In re Unroe
  937 F.2d 346· 7th Cir.· 1991-07-15 ·cited 12×
  The court held that while the late-filed IRS claim did not relate back under Fed.R.Civ.P. 15(c), the bankruptcy court did not abuse its discretion in allowing the claim based on equitable principles and the debtor's notice of the claim.
• Merritt v. Cnty. OF LOS Angeles
  875 F.2d 765· 9th Cir.· 1989-05-24 ·cited 11×
  The court held that the district court erred in denying the motion to amend based on federal notice requirements, and that the grant of judgment notwithstanding the verdict for the County was proper due to insufficient evidence of a policy of inadequate training.
• Berndt v. State OF Tenn. & Lakeshore Mental Health Inst.
  796 F.2d 879· 6th Cir.· 1986-07-22 ·cited 11×
  The court held that while the State of Tennessee and LMHI are immune from suit under the Eleventh Amendment, the case should be remanded to allow the pro se plaintiff to amend his complaint to name individual state officials as defendants.
• Bates v. Tenn. Valley Auth. & Orvis Engelstad
  851 F.2d 1366· 11th Cir.· 1988-08-10 ·cited 10×
  The court held that an amendment to add parties after the limitations period expired could not relate back under Federal Rule of Civil Procedure 15(c) because the new parties did not receive notice within the limitations period.
• Sassi v. Breier
  584 F.2d 234· 7th Cir.· 1978-10-06 ·cited 10×
  An amended complaint substituting named defendants for 'John Doe' does not relate back to the original filing if the newly named defendants lacked notice of the action within the limitations period.
• Kilkenny v. Arco Marine Inc.
  800 F.2d 853· 9th Cir.· 1986-09-19 ·cited 9×
  The court held that an amendment to a complaint adding new defendants does not relate back under Rule 15(c) if the new defendants did not have notice of the mistake concerning their identity within the original limitations period.
• USM Corp. v. GKN Fasteners Ltd.
  578 F.2d 21· 1st Cir.· 1978-07-12 ·cited 9×
  Amended pleadings that attempt to retroactively establish appellate jurisdiction do not relate back to validate an untimely appeal.
• Slaughter v. S. Talc Co.
  949 F.2d 167· 5th Cir.· 1991-12-23 ·cited 6×
  The court held that circumstantial evidence of exposure to asbestos-containing products can be sufficient to withstand summary judgment, but insufficient evidence linking inhaled talc to asbestos content warrants summary judgment for the talc supplier. The court also held that su
• Winnie Marchant v. City OF Little Rock
  741 F.2d 201· 8th Cir.· 1984-08-21 ·cited 6×
• Branchcomb v. Lou Brewer
  683 F.2d 251· 8th Cir.· 1982-07-14 ·cited 6×
  The court held that the trial court's finding of no deliberate indifference by the named defendants was not clearly erroneous, but vacated the dismissal of claims against two other defendants based on a change in the applicable statute of limitations.
• Diaz v. Shallbetter
  984 F.2d 850· 7th Cir.· 1993-01-28 ·cited 4×
  The court held that the amended version of Fed.R.Civ.P. 15(c) should be applied retroactively to cases pending on appeal, as indicated by the Supreme Court's order.
• Gardner v. Gartman
  880 F.2d 797· 4th Cir.· 1989-07-27 ·cited 4×
  The court held that the plaintiff's failure to name the Secretary of the Navy as a defendant within the statutory limitations period barred relation back of her amended complaint, and thus the dismissal was proper.
• Percy v. SAN Francisco Gen. Hosp.
  841 F.2d 975· 9th Cir.· 1988-03-10 ·cited 4×
  The court held that a claim for denial of due process in a Civil Service Commission hearing does not relate back to an original complaint alleging racial discrimination in termination under Title VII, as they arise from different conduct and transactions.
• United States v. Currency $267
  916 F.2d 1104· 6th Cir.· 1990-10-22 ·cited 2×
  The court held that the district court did not abuse its discretion in denying leave to further amend the claim.
• Fed. Deposit Ins. Corp. v. Bennett
  898 F.2d 477· 5th Cir.· 1990-04-18 ·cited 2×
  The court held that the FDIC's amended complaint to claim redemption under 28 U.S.C. § 2410(c) related back to the original complaint under Fed.R.Civ.P. 15(c), thus avoiding the statute of limitations.
• Ely A. Martell v. Trilogy Ltd.
  872 F.2d 322· 9th Cir.· 1989-04-10 ·cited 2×
  The court held that when a plaintiff seeks to amend a complaint to state a new claim against a party already named in the action, the more lenient transactional test of Rule 15(c) applies, not the stricter test for changing parties.
• Tidewater Marine Towing, Inc. v. DOW Chem. Co., Inc.
  689 F.2d 1251· 5th Cir.· 1982-10-28 ·cited 2×
  A claimant must be the decedent's personal representative to bring a wrongful death action under general maritime law, even if they are a potential beneficiary.
• Besig v. The Dolphin Boating & Swimming Club
  683 F.2d 1271· 9th Cir.· 1982-08-12 ·cited 2×
  The court held that the disparate treatment of members and nonmembers in accessing club facilities, as established by the Park Commission, did not violate the Equal Protection Clause because it was rationally related to legitimate governmental interests. The court also held that
• Margherita Cunningham v. Centurion of Fla., LLC
  N.D. Fla.· 2025-12-23
  The court held that the plaintiff's claims were barred by the statute of limitations and failed to state a claim for deliberate indifference, as the amended complaint did not relate back to the original complaint and lacked sufficient factual allegations.
• Hoke v. Walker
  N.D. Fla.· 2025-05-02
  The court held that claims against defendants Jackson and Quam are time-barred by the statute of limitations, while claims against defendant Porter may proceed because they relate back to the original pleading.
• Deffendall v. Indian River Cnty. Sheriff
  S.D. Fla.· 2023-11-24
  A pretrial detainee incarcerated in a Florida jail brought a Section 1983 claim alleging that corrections officers failed to protect him from attack by another inmate and that medical staff violated his constitutional rights by failing to follow post-operative pain management ins
• Torres v. Sec'y, Dep't of Corr. (Hardee County)
  M.D. Fla.· 2021-07-21
  Jose Antonio Torres sought federal habeas corpus relief challenging his Florida state conviction for kidnapping and the second-degree murder of Malik Muhammad, arguing that his trial counsel provided ineffective assistance in various ways, including failing to move to suppress ev
• Harris v. Wingo
  M.D. Fla.· 2020-11-05
  The court held that the amended complaint adding Deputy Pepin as a defendant does not relate back to the original complaint because there was no mistake concerning the proper party's identity, and Florida law generally prohibits adding new parties after the statute of limitations
• Broomfield v. United States
  M.D. Fla.· 2020-08-10
  The court held that Petitioner's claims of ineffective assistance of counsel lacked merit because counsel's actions were reasonable or did not prejudice the defense, and the claims regarding prosecutorial authority were time-barred.
• Ring v. Boca Ciega Yacht Club, Inc
  M.D. Fla.· 2019-11-07
  The court held that the plaintiff has standing to pursue her ADA claims, and these claims are not moot despite her expulsion from the club. The court also found that the plaintiff's FCRA claim may proceed, as she sufficiently exhausted administrative remedies by filing with a loc
• Grand Lodge of Pa. v. Peters
  560 F. Supp. 2d 1270· M.D. Fla.· 2008-06-06
  The court held that the addition of a new plaintiff, Villere, was permissible and related back to the original filing, and that the statute of limitations was tolled, allowing the Section 11 and 15 claims to proceed.
• Nw. Acceptance Corp. v. Lynnwood Equip., Inc.
  834 F.2d 823· 9th Cir.· 1987-12-16
  The security agreement's description of collateral governs the extent of the security interest, not the financing statement. Failure to provide notice of sale does not bar a deficiency judgment. Novation defense was waived. Collateral estoppel applied to the commercial reasonable
• W.H. Farner v. Fireman's Fund Ins. Co.
  748 F.2d 551· 10th Cir.· 1984-11-16
  The court held that claims against the law firms were time-barred due to the statute of limitations and failure to relate back, but the claim against the insurance company for breach of duty to defend was timely under the four-year statute of limitations.
• Young v. Pick Hotels-Washington Corp.
  420 F.2d 247· D.C. Cir.· 1969-05-19
  The court held that the amended complaint relating back to the original filing date satisfied Rule 15(c) requirements, and the case should not have been dismissed on statute of limitations grounds.