## Facts

- Five seamen worked for years aboard vessels owned or operated by various shipowners and operators.
- Each seaman was diagnosed with leukemia and died in 1987–1989.
- Between 1990 and 1992, the estate administrator filed five federal actions under the Jones Act and general maritime law asserting survival and wrongful-death claims.
- The original complaints (substantively identical across cases) alleged that the decedents were exposed aboard defendants’ vessels to “asbestos and other hazardous substances,” causing leukemia and death.
- The district court later ordered amended complaints to clarify the liability theory and identify the specific cargo or substances alleged to have contained benzene.
- In 1997, the administrator filed amended complaints that emphasized exposure to benzene and benzene-containing products (along with other hazardous substances) as the cause of leukemia and death.
- Defendants argued the amended pleadings asserted new, time-barred claims under the Jones Act’s three-year limitations period.

## Issues

1. Whether the 1997 amended complaints alleging benzene-based causation “relate back” under Federal Rule of Civil Procedure 15(c)(2) to the timely 1990–1992 complaints alleging exposure to asbestos and “other hazardous substances.”
2. Whether, absent relation back, the amended benzene allegations are barred by the Jones Act’s three-year statute of limitations.

## Decision

- The court of appeals reversed the district court.
- It held the amended complaints related back under Rule 15(c)(2) because they arose from the same conduct, transaction, or occurrence described in the original pleadings.
- It concluded the defendants had adequate notice from the original complaints that the claims concerned shipboard exposure to toxic substances causing leukemia and death, and that later specifying benzene did not create an unfair surprise.
- The case was remanded for further proceedings.

## Legal Principles

- Under Rule 15(c), an amendment relates back when the amended claim arises out of the same conduct, transaction, or occurrence attempted to be set forth in the original pleading.
- The relation-back inquiry turns on whether the original pleading provided fair notice of the general factual situation forming the basis of the claim, not on whether the original pleading identified the same chemical agent or legal theory in detail.
- In occupational-disease cases, amendments that refine causation allegations (e.g., identifying a particular toxin) may relate back when they concern the same workplace, time period, injury, and alleged exposure event described initially.
- A Jones Act claim is subject to a three-year limitations period; relation back can avoid time-bar consequences when the original pleading timely put the defendant on notice of the operative facts.

## Conclusion

The court held that amendments shifting from a general toxic-exposure allegation to a benzene-specific causation theory related back to the timely Jones Act pleadings because both sets of complaints rested on the same alleged shipboard exposure during the same employment resulting in the same leukemia deaths, so the claims were not barred by limitations.


Miller v. Am. Heavy Lift Shipping, 231 F.3d 242 (6th Cir. 2000)