Facts
- Wanda Krupski was injured in February 2007 while traveling as a passenger on a cruise ship owned and operated by Costa Crociere S.p.A.
- The passenger ticket identified Costa Crociere as the contractual “carrier,” imposed a one-year period to sue, and specified an exclusive federal forum; the ticket also listed a Florida address for Costa Cruise Lines N.V., the North American sales and booking agent, and referred to “Costa Cruises.”
- Krupski provided written notice of her claim to Costa Cruise but did not settle.
- Before the one-year contractual limitation period expired, Krupski filed a negligence action in federal court naming Costa Cruise as the defendant; the limitation period expired about three weeks later.
- After expiration, Costa Cruise repeatedly asserted in filings that Costa Crociere was the proper defendant, including in a summary judgment motion.
- Krupski sought leave to amend to add Costa Crociere; the district court granted leave, the amended complaint was served on Costa Crociere, and Costa Cruise was dismissed by stipulation.
- Costa Crociere, represented by the same counsel as Costa Cruise, moved to dismiss the amended complaint as time-barred, arguing it did not relate back under Federal Rule of Civil Procedure 15(c).
- The district court and the Eleventh Circuit held relation back unavailable, emphasizing Krupski’s awareness of Costa Crociere from the ticket and her delay in amending.
Issues
- Under Federal Rule of Civil Procedure 15(c)(1)(C), whether relation back for an amendment changing the defendant turns on the plaintiff’s knowledge and diligence or on what the newly added defendant knew or should have known within the Rule 4(m) period.
- Whether a plaintiff makes a “mistake concerning the proper party’s identity” when she sues a related corporate entity despite having information identifying the correct entity.
- Whether Costa Crociere had sufficient notice and reason to know it was the intended defendant so that adding it after the limitations period relates back.
Decision
- The Supreme Court reversed the Eleventh Circuit and remanded.
- Relation back under Rule 15(c)(1)(C) depends on what the party to be added knew or should have known within the Rule 4(m) period, not on the plaintiff’s knowledge or timeliness in seeking to amend.
- The Court concluded Costa Crociere knew or should have known, within the Rule 4(m) period, that it would have been named as a defendant but for a mistake about the proper party’s identity.
- The Court held that Krupski’s amended complaint related back to the original filing date and was therefore timely.
Legal Principles
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Rule 15(c)(1)(C) permits an amendment changing the party or naming a new party to relate back when the claim arises from the same conduct, transaction, or occurrence and, within the Rule 4(m) period, the added party:
- received notice such that it will not be prejudiced in defending; and
- knew or should have known the action would have been brought against it but for a mistake concerning the proper party’s identity.
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The “mistake” inquiry centers on the added defendant’s understanding of why it was not sued initially, not on whether the plaintiff knew or should have known the added defendant’s identity.
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A plaintiff can make a qualifying “mistake” even if she was aware the added defendant existed, including when she misapprehends the roles of related corporate entities with similar names.
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Post-limitations delay in moving to amend does not control the Rule 15(c)(1)(C)(ii) analysis, though it may bear on other procedural questions (such as leave to amend).
Conclusion
The Court held that Rule 15(c) relation back for a change of defendant turns on the added defendant’s notice and knowledge during the Rule 4(m) period and that confusion between closely related corporate entities can constitute a “mistake” allowing relation back, making Krupski’s amended complaint timely.