Brief Fact Summary. Plaintiff, Dorothy Singletary, appeals a District Court summary judgment for the Defendant, Pennsylvania Department of Corrections (“PADOC”) et al. Plaintiff also seeks to amend her complaint to add another Defendant, Robert Regan.
Synopsis of Rule of Law. Under Rule 15(c), a plaintiff can relate an amended claim back to the original if the amended claim arose from the same conduct and the newly added party was sufficiently notified within 120 days after the initial complaint was filed.
The requirements of the rules of procedure should be liberally construed, however, and mere technicalities should not stand in the way of consideration of a case on the merits.View Full Point of Law
Issue. The issue is whether Plaintiff can amend her complaint under Fed. R. Civ. P. 15(c) to substitute Regan as a party instead of “Unknown Corrections Officers”.
Held. The Court held that Plaintiff should not be allowed to amend her complaint and name Regan as a Defendant. Under Rule 15(c), a plaintiff can relate an amended claim back to the original if the amended claim arose from the same conduct and the newly added party was sufficiently notified within 120 days after the initial complaint was filed. The court held that Regan was not sufficiently notified because there was no actual notice, and Plaintiff’s arguments for constructive notice were rejected. There was no notice via sharing an attorney because Regan did not share the attorney in the first 120 days. There was no notice via an identity of interest with the original Defendants because Regan was a mid-level employee who would not likely have any idea of litigation against his employer.
Discussion. Rule 15(c) is designed to ensure that a party would not be prejudiced by the delay in being named to the suit. In this case, Plaintiff attempted to ad Regan to the suit almost two years after the statute of limitations has run.