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Also known as:relation-back of amended pleadings · relates back · relating back · relation back doctrine · Rule 15(c) · relation back
Written by attorneys — see sources below.
A procedural doctrine under which an amended pleading is treated as filed on the date of the original pleading for statute of limitations purposes. The doctrine applies when the law supplying the applicable limitations period authorizes relation back or when the amendment asserts a claim arising from the same conduct, transaction, or occurrence set out in the original pleading.
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How its tested
Common Examples
2
State Limitations Law Permits Relation Back
Rebecca Ross sued Valley Regional Bank in federal court for common-law misrepresentation in the sale of notes. After the state blue-sky statute of limitations expired, she moved to amend to add state statutory securities-fraud claims based on the same offering documents. The forum state's law expressly allows such statutory claims to relate back whenever they rest on those same documents. The court treats the amended claims as timely filed because the state limitations law authorizes relation back on these facts.
Amendment Adds Claim From Same Transaction
Rhea Reynolds sued Apex Industries for breach of contract on unpaid invoices under a master licensing order. After the statute of limitations expired, she moved to amend to add a claim that the same nonpayment also breached a minimum user-license purchase requirement in that order. The court treats the proposed amendment as relating back because the new claim arises from the identical nonpayment transaction already pleaded in the original complaint.
United States Parole Commission v. Geraghty445 U.S. 388, 400 (1980)
In 1973 the United States Parole Board adopted explicit Parole Release Guidelines that established a customary range of confinement by combining a parole prognosis score with an offense severity rating.
On January 25, 1974, respondent John M. Geraghty was convicted in the Northern District of Illinois of conspiracy to commit extortion and making false material declarations to a grand jury and was sentenced to concurrent terms of four years and one year. The Seventh Circuit affirmed the convictions. Geraghty later obtained a reduction of his sentence to 30 months through a Rule 35 motion.
Geraghty applied for parole in January 1976 and again in June 1976. Both applications were denied because his offense behavior was rated very high severity, his salient factor score was 11, and the guidelines indicated a range of 26-36 months. He then instituted this civil suit as a class action in the United States District Court for the District of Columbia, challenging the guidelines as inconsistent with the PCRA and the Constitution, and questioning the procedures by which the guidelines were applied to his case.
The case was transferred to the Middle District of Pennsylvania where Geraghty was incarcerated. The district court denied class certification as neither necessary nor appropriate and granted summary judgment for the defendants on all claims. Geraghty appealed to the Third Circuit individually and on behalf of the proposed class. Another prisoner represented by the same counsel moved to intervene.
On June 30, 1977, before any briefs were filed, Geraghty was mandatorily released after serving 22 months of his sentence. The Parole Commission moved to dismiss the appeals as moot. The Third Circuit held the litigation was not moot, reversed the denial of class certification, and remanded for further proceedings including evaluation of subclasses.
The Supreme Court granted certiorari to resolve the conflict among the courts of appeals on whether a class action challenging parole guidelines becomes moot when the named plaintiff is released from prison while the appeal from denial of class certification is pending.
When does federal procedure allow an amended pleading to relate back based on state limitations law?
Federal procedure permits relation back when the law providing the applicable statute of limitations itself authorizes relation back under the circumstances. In a diversity case the court looks to the state limitations scheme when it directly addresses relation back for the type of claim at issue.
Supporting sources
Does an amendment adding a new legal theory from the same facts relate back?
An amended claim relates back when it arises out of the same conduct, transaction, or occurrence set out in the original pleading. The focus is whether the original pleading gave fair notice of the core factual situation so the defendant is not prejudiced by the late-added theory.
Supporting sources
May a federal court apply a more generous state relation-back rule in a diversity case?
Yes. When a plaintiff sues under state law and the state statute of limitations supplies the time bar, federal procedure incorporates the state's rules on relation back if those rules are more generous than the ordinary federal standard.
Supporting sources
What controls relation back when adding a new defendant after limitations has run?
For Rule 15(c)(1)(C) relation back when changing or adding a defendant, the key inquiry is what the party to be brought in knew or should have known within the Rule 4(m) period—that but for a mistake concerning the proper party's identity, the action would have been brought against it.
Supporting sources
560 U.S. 538 (2010)
…the plaintiff knew or should have known of the proper defendant before filing her original complaint. The court also held that relation back was not appropriate because the plaintiff had unduly delayed in seeking to amend. We hold that relation back under Rule 15(c)(1)(C) depends on what the party to be added knew or should have…
Civil ProcedurePretrial procedures · Pleadings and amended pleadingsNEXTGENFoundational