United States Court of Appeals for the Eleventh Circuit - 130 S. Ct. 2485
In the case of Krupski v. Costa Crociere S.P.A. (2010), the US Supreme Court dealt with the issue of relation back of amendments in federal civil suits. Wanda Krupski, the plaintiff, sought compensation for injuries she sustained on a cruise ship operated by Costa Crociere, the defendant. However, Krupski initially sued Costa Cruise Lines within the required one-year period. Krupski eventually amended her complaint to add Costa Crociere, under Rule 15 (a) of the Federal Rules of Civil Procedure, after the one-year period elapsed.
The district court allowed the amendment but Costa Crociere claimed Krupski's amended complaint didn't relate back to her original complaint under Rule 15©. The Court of Appeals agreed, stating that Krupski's decision to sue Costa Cruise was a deliberate choice, not a mistake.
The Supreme Court reversed this judgment, ruling that Krupski's amended complaint did relate back under Rule 15© because Costa Crociere should have known they would be named as a defendant. The Court emphasized that relation back depends on what the newly named party knew or should have known and not what the amending party knew. This rule maintains a balance between the parties, avoiding prejudice to defendants and forfeiture for plaintiffs. Lastly, the Court found Krupski made a mistake and Costa Crociere suffered no prejudice because of the delay in amending her complaint. This case highlights the principles and limitations of relation back of amendments in federal courts.
The case involves a passenger who was injured on a Costa Cruise Lines ship. The passenger ticket required that any injured party must provide written notice of the claim with full particulars to the carrier or its authorized agent within 185 days after the date of injury. The ticket also required that any lawsuit must be filed within one year after the date of injury and served upon the carrier within 120 days after filing. The Supreme Court held that relation back under Rule 15(c)(1)(C) depends on what the party to be added knew or should have known, not on the amending party's knowledge or its timeliness in seeking to amend the pleading. The District Court and the Eleventh Circuit erred in their interpretation of Rule 15(c)(l)(C)(ii).
Justice Scalia agrees with the Court's opinion in the legal case, except for its reliance on the Advisory Committee's Notes to interpret Federal Rule of Civil Procedure 15(c)(1)(C). He argues that the Committee's intentions do not impact the meaning of the Rule, and that it is the text of the Rule that governs. Scalia cites Tome v. United States to support his position. However, it should be noted that Scalia's argument differs from the Court's interpretation of the Rule.
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