## Facts

- Edward Singletary, an inmate at a Pennsylvania state prison, was placed in maximum security after making threats and was seen by mental-health staff, including a prison psychologist.
- Mental-health personnel met with him over time and did not believe he was suicidal.
- Edward Singletary died by suicide while incarcerated.
- On October 6, 1998, the last day of Pennsylvania’s two-year limitations period for § 1983 claims, Dorothy Singletary filed suit individually and as administrator of Edward’s estate.
- The complaint asserted § 1983 deliberate-indifference claims and related state wrongful-death claims against the state corrections department, the prison, the superintendent, and “Unknown Corrections Officers.”
- After discovery, the plaintiff sought to amend the complaint (July 28, 2000) to add the prison psychologist as a defendant, effectively substituting him for an “Unknown Corrections Officer,” and relied on Rule 15(c) relation back to avoid the time bar.

## Issues

1. Whether the evidence supported § 1983 supervisory liability against the prison superintendent for deliberate indifference to the inmate’s serious medical needs.
2. Whether an amended complaint adding an individual prison employee after the statute of limitations expired related back under Federal Rule of Civil Procedure 15(c) based on timely notice and “mistake concerning the identity of the proper party.”

## Decision

- The Third Circuit affirmed summary judgment for the superintendent because the record did not support deliberate indifference.
- The Third Circuit affirmed denial of leave to amend to add the psychologist because the amendment did not relate back under Rule 15(c).
- The court held the plaintiff failed to satisfy Rule 15(c)’s notice requirement within the Rule 4(m) period and indicated substantial doubt that the “mistake” requirement was met.

## Legal Principles

- Rule 15(c) relation back for adding a new party requires: (1) the claim arises from the same conduct, transaction, or occurrence; (2) within the Rule 4(m) service period, the new party received notice of the action so it will not be prejudiced; and (3) within that period, the new party knew or should have known the action would have been brought against it but for a mistake about identity.
- Absent actual notice within the Rule 4(m) period, notice may be imputed in limited circumstances, including:
  - Shared-attorney notice, where counsel’s involvement with both the original defendants and the proposed defendant during the notice period supports an inference the proposed defendant learned of the suit; and
  - Identity-of-interest notice, where the relationship between the original and proposed defendants is sufficiently close to support imputation.
- A non-supervisory, mid-level employee generally does not share an identity of interest with an institutional employer sufficient, by itself, to impute notice of litigation to the employee.
- Naming “Unknown” defendants does not, without more, establish the Rule 15(c) requirements for timely notice and a qualifying “mistake” as to the new party’s identity.

## Conclusion

The Third Circuit held that the plaintiff’s only potentially viable § 1983 claim—against an individual psychologist—was time-barred because the plaintiff could not meet Rule 15(c)’s notice requirements (and likely could not show a qualifying mistake) to relate the late amendment back to the timely filed complaint, and it also affirmed summary judgment for the superintendent for lack of evidence of deliberate indifference.


Singletary v. Pa. Dep’t of Corr., 266 F.3d 186 (3d Cir. 2001)