Krupski v. Costa Crociere, S.A.

Brief Fact Summary.

Petitioner originally filed a personal injury action against “Costa Cruise Lines N.V., L.L.C.” She subsequently dismissed the claims against the original defendant and amended her complaint to add  Costa Crociere as Defendant. Costa Crociere moved to dismiss the amended complaint. The district court granted the motion, finding that the amended complaint did not relate back to the original complaint and was therefore untimely. The court of appeals affirmed.

Synopsis of Rule of Law.

The question under Rule 15(c)(1)(C) is what the prospective defendant knew or should have known, not what the plaintiff should have known upon filing her original complaint. Also, the amending party’s diligence in filing an amended complaint does not justify the denial of relation back.

Facts.

Petitioner tripped and broke her leg while on a cruise ship. She filed a personal injury action against “Costa Cruise Lines N.V., L.L.C.” Subsequently, Petitioner dismissed claims against the original defendant, as an improper defendant, and moved for leave to amend her complaint to add  Costa Crociere as Defendant. The district court granted leave to amend. Costa Crociere thereafter moved to dismiss, claiming that the complaint against it did not relate back to the original complaint under Federal Rule of Civil Procedure 15(c)(1)(C) and was therefore untimely. The district court agreed, and the United States Court of Appeals for the Eleventh Circuit affirmed.

Issue.

Did the Court of Appeals correctly deny relation back under Rule 15(c)(1)(C)?

Held.

No. The Court of Appeals erred in denying relation back.

Discussion.

Costa Crociere should have known that Petitioner’s failure to name it in the original complaint was due to a mistake in the identity of the proper party.