## Facts

- Susanna Jeffrey was rear-ended while stopped in traffic while driving a 1986 Chevrolet Blazer and wearing her seat belt.
- She struck her face on the steering wheel and suffered serious facial and brain-related injuries.
- During a neuropsychological evaluation, Jeffrey stated that she hit the steering wheel because the seat belt “didn’t hold” her or “failed,” and the evaluator’s report to counsel recorded that description.
- Within one year of the accident, Jeffrey sued the rear-ending driver and multiple Doe defendants for her injuries.
- More than two years after the accident, Jeffrey substituted General Motors Corporation (GM) for a Doe defendant and asserted product-liability claims alleging a defective seat belt design, including a “comfort feature” that allowed slack to be introduced and reduced restraint.
- GM contended Jeffrey could not use Doe pleading because she knew GM was the manufacturer and knew from the outset that the seat belt did not restrain her.

## Issues

1. Whether Code of Civil Procedure § 474 permits relation back when the plaintiff knew the manufacturer’s identity and perceived that the belt did not restrain her, but did not know facts supporting a specific design-defect theory when the original complaint was filed.
2. Whether the trial court erred by denying GM’s motion to quash service as time-barred and whether writ relief was warranted.

## Decision

- The Court of Appeal denied GM’s petition for writ of mandate.
- The court upheld the trial court’s order denying GM’s motion to quash service of summons.
- The court held that Jeffrey’s amendment substituting GM for a Doe defendant satisfied § 474 and related back to the original complaint’s filing date.

## Legal Principles

- Under Code of Civil Procedure § 474, a plaintiff may designate a defendant by a fictitious name and later amend to state the true name; if § 474 applies, the amendment relates back to the original filing date for limitations purposes.
- “Ignorance” under § 474 is not limited to lack of the defendant’s literal name; it includes lack of knowledge of facts showing the defendant’s connection to liability, including ignorance of facts giving rise to a cause of action against a known entity.
- A lay understanding that “something went wrong” during an accident (e.g., a seat belt “failed” to restrain) does not necessarily establish knowledge of a technical product defect or facts indicating the manufacturer’s legal responsibility.
- Where the record supports that the plaintiff did not know the factual basis for a product-defect claim at the time of the original complaint, denial of a motion to quash on limitations grounds is proper and extraordinary writ relief is inappropriate.

## Conclusion

The court allowed a late-named manufacturer to be added by Doe substitution because the plaintiff’s early awareness that the seat belt did not restrain her did not equate to knowledge of facts supporting a design-defect claim; therefore, the amendment related back under § 474 and the products-liability claims were not time-barred.


General Motors Corp. v. Superior Court, 48 Cal. App. 4th 580, 55 Cal. Rptr. 2d 871 (Cal. Ct. App. 1996)