Krupski v. Costa Crociere S.P.A. case brief
Posture: Suit brought in Florida District court under diversity. District court denied summary judgment and allowed plaintiff to amend complaint to bring in Costa Crociere. Costa Cruise was dismissed and Crociere was brought in who moved to dismiss saying that amended complaint did not relate to Rule 15 (c) and was untimely, case dismissed. Court decided that plaintiff knew for a while Crociere should have been sued but they did not, it was plaintiffs deliberate mistake and should be so punished. Appeals affirmed, SCOTUS reverses.
Facts: Plaintiff tripped over a cable on the cruise ship, Costa Magica, which was operated by Costa Crociere. However, plaintiff sued Costa Cruise Lines for Plaintiff’s claims. Costa Cruise is a North American sales and marketing agent for Costa Crociere, they have nothing to do with vessels. They tried to work out a settlement but when they couldn’t, a diversity suit was filed in Florida court. Costa Cruise told plaintiff of Costa Crociere three times and asserted it was not proper defendant since it is just marketing. Plaintiff brought in a lot of evidence to say that she believed Costa Cruise was right defendant and amended her complaint which was allowed. She followed courts deadline and brought in Crociere but they moved to dismiss for untimely complaint amendment.
Reasoning: Court said that ct of appeals was wrong in decision. It said that the ct of appeals asked if plaintiff knew whether or not that Crociere was proper defendant, but this was wrong. Rule 15 asks what defendant knows and whether Crociere knew that but for it was a mistake, they would have been named as a defendant. The only reason to look at plaintiffs intent is to see if plaintiff knew that suing Costa Cruise would not be the same as suing Crociere. If plaintiff did know, then case dismissed but if she did not know then case should continue. That is the important point here. Plaintiff believed she made no mistake in suing cruise since she thought it was same thing as Crociere.
Also, found that the speed at which a plaintiff amends does not have any bearing on whether complaint “relates back”
Concurrence: Justice Scalia: Thought that notes of advisory committee stating intent was irrelevant.