Worthington v. Wilson

Brief Fact Summary.

Plaintiff amended his complaint naming two police officers as the Defendants. Defendants moved to dismiss the complaint for passing the statute of limitations and failing to state a claim under § 1983.

Synopsis of Rule of Law.

Under Rule 15(c), an amended complaint does not sufficiently relate back to the original when it corrects a lack of knowledge rather than a mistake.

Facts.

In 1989, Richard Worthington (Plaintiff) was injured by Officers Wilson and Wall (Defendants) while being arrested. Two years later, Plaintiff brought suit for violation of his rights under 42 U.S.C. § 1983 against Village of Peoria Heights and three unknown police officers. Four months later, Plaintiff amended his complaint, naming the two Defendants as the officers that had injured him. Defendants moved to dismiss the amended complaint for passing the statute of limitations and failing to state a claim under § 1983.

Issue.

Did Plaintiff’s amended complaint sufficiently relate back to the original complaint, under Rule 15(c), so as not to be barred by the statute of limitations?

Held.

No, the amended complaint did not sufficiently relate back to the original complaint and is barred by the statute of limitations. The Defendant’s motion to dismiss is granted.

Discussion.

The Court determined that Plaintiff’s amended complaint did not relate back to the original under Rule 15(c). Though the Defendants were aware that they were the unnamed officers in the original complaint, Plaintiff conceded that his original complaint listed “unknown” officers based on lack of knowledge and not as a mistake.