Summary of Krupski v. Costa Crociere
Citation: 560 U.S. ______, 130 S.Ct. 2485 (2010)
Relevant Facts: Wanda Krupski, while on a cruise operated by the Respondent, tripped over a cable and fractured her leg. Upon her return home, Krupski hired an attorney to assist her in seeking compensation for her injuries. Appellant purchased her ticket from Costa Cruise, and her ticket specified both that any injury claims must be filed within one year and that any claims would be against the “carrier." After unsuccessful settlement negotiations, Krupski’s attorney filed suit against Costa Cruise within the one year limit. Thereafter, Costa Cruise – through their answer and on two other occasions – informed Krupski that they were merely the marketing and sales agent for Costa Crociere and not the proper defendant. After Costa Cruise moved for summary judgment, Krupski sought to amend her complaint and add Costa Crociere as the proper defendant. The district court denied Costa Cruise’s motion for summary judgment, allowed Krupski to amend her complaint, and then agreed to dismiss Costa Cruise by consent after Costa Crociere was added as a defendant. Costa Crociere then moved to dismiss the action as untimely, citing the one year limitation period. While Krupski had brought the original action within one year, Costa Crociere was not added as a party until after one year had passed. Krupski argued that the date of the action should relate back to the original filing date under Rule 15(c) of the Federal Rules of Civil Procedure. Costa Crociere argued that the plaintiff had not made a mistake, as required by Rule 15, but rather had deliberately chosen not to sue Costa Crociere in favor of Costa Cruise and did not seek to amend the complaint even after being informed that Costa Crociere was the proper defendant. The district court agreed with the defendant, citing the undue delay in amending the complaint. The Eleventh Circuit affirmed, concluding that Krupski either knew or should have known who the proper defendant was, and similarly concluding that undue delay defeated any effort to relate back the date of the complaint.
Issue: What constitutes a legitimate mistake as to the identity of the proper defendant under Rule 15(c) of the Federal Rules of Civil Procedure such that the time of filing properly relates back to the original filing even though the proper defendant was only subsequently added?
Holding: The proper interpretation of relation back under Rule 15(c) depends on what the proper defendant knew or should have known rather than what the plaintiff knew. In this case, the proper defendant had notice of the claims at issue such that subsequent amendment to name the proper defendant should properly relate back to the original filing.
Reasoning: Justice Sotomayor delivered the opinion of the Court. As the majority explained, the Eleventh Circuit erred in adopted an interpretation of Rule c(1)C(ii) unsupported by the language of the rule itself. Under the actual language of the Rule, complaints relate back to the original filing date if the proper defendant knew or should have known it was the proper defendant but for the plaintiff’s mistake. Justice Sotomayor explained that the Court below mistakenly conflated knowledge of another party’s existence with the absence of mistake regarding the proper defendant’s identity. While the plaintiff here was aware that Costa Crociere existed, they mistakenly believed that their claim was properly directed at Costa Cruise. While the defendant argued that the original complaint represented a deliberate choice to sue one entity rather than another, the Court concluded that the plaintiff was mistaken about the true identity of the similarly named corporate entities. Furthermore, as the majority explained, the Federal Rules should be liberally construed to favor judgments on the merits, and the holding here is consistent with the notice requirements of Rule 4. Next, the Court explained that the Eleventh Circuits analysis of plaintiff delay in amending the complaint was improper. Under the text of the applicable rule, relation back is mandatory once the plaintiff has satisfied the exclusive list of requirements- requirements that do not include diligence in amending the complaint. Thus, while the plaintiffs conduct is relevant to determining proper notice to the defendant under Rule 4, plaintiff conduct (and lack of diligence) is irrelevant to whether the complaint relates back. Furthermore, federal courts do not have equitable discretion as to whether complaints should relate back. Finally, the Court explained that upon applying the proper standard, the plaintiff’s complaint here relates back to the original filing. The allegations in the complaint itself make clear that the plaintiff was mistaken as to the identity of the proper defendant. Furthermore, the proper defendant contributed to the misunderstanding and should have been aware of the potential for mistakes given other, previous errors regarding the same misunderstanding. The proper defendant, Costa Crociere, represented by the same counsel as the original defendant was aware of the plaintiff’s claim within the applicable time limitation and subsequent amendment to correct the plaintiff’s mistake relates back to the original filing. Accordingly, the plaintiff’s case was timely as the amended complaint related back to date of the original filing.
Concurrence: Justice Scalia concurred in part and concurred in the judgment. He disagreed with the majority’s reliance upon the Notes of the Advisory Committee, pointing out that they should be afforded the same weight as other scholarly commentary. In his opinion, the Court attempted to effectuate the intentions of the Committee rather than interpret the text of the Rule actually adopted.
Conclusion: Under Rule 15c(1)C(ii), plaintiffs’’ claims will relate back to the original filing when they have made a mistake as to the identity of the proper defendant and that defendant has notice of the claim within the applicable limitations period. The relevant inquiry is notice to the defendant rather than when the plaintiff discovered the mistake necessitating amendment.