Saturday, December 7, 2013

Worthington v. Wilson case brief

Worthington v. Wilson case brief summary
790 F. Supp. 829 (1992)

Plaintiff criminal filed an amended 42 U.S.C.S. § 1983 civil rights complaint against defendants, three police officers who had previously arrested him. Thereafter, the police officers moved to dismiss the action on multiple bases including statute of limitations grounds.

The criminal was injured during his arrest by the police officers. Some two years later he filed a civil rights action per § 1983 that named the police officers and a village as defendants. After the village was dismissed as a defendant, the criminal filed an amended complaint that named the police officers as defendants. Thereafter, the police officers moved to dismiss the complaint on statute of limitations grounds and for a failure to state a claim for relief. Since the amended complaint was not filed until after the expiration of the relevant limitations period, the only way the amended complaint could be found to be timely filed was if it related back to the filing of the original complaint.

  • The court noted that while Fed. R. Civ. P. 15(c)permits amendments which change a mistaken name in the original complaint, it did not permit a plaintiff to replace "unknown" parties with actual parties. 
  • Thus, the court held that the criminal's amended complaint did not relate back under Rule 15(c) because the amendment did not correct a "mistake," but rather corrected a lack of knowledge at the time of the original complaint. 
  • The criminal's complaint therefore was dismissed.
The criminal's civil rights complaint against the police officers was dismissed on statute of limitations grounds.

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