Krupski v. Costa Crociere S.P.A.
560 U. S. ____ (2010) (2010)
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Rule of Law:
Relation back of an amended pleading under Federal Rule of Civil Procedure 15(c)(1)(C) depends on what the newly added party knew or should have known, not on the plaintiff's knowledge of the proper party's identity or the plaintiff's diligence in seeking to amend the complaint.
Facts:
- On February 21, 2007, Wanda Krupski was injured when she tripped over a cable on the cruise ship Costa Magica.
- Krupski's passenger ticket identified the carrier as 'Costa Crociere S. p. A., an Italian corporation.'
- The ticket also identified 'Costa Cruise Lines N. V' as the sales and marketing agent and listed its Florida address.
- The ticket contained a one-year limitations period for filing any lawsuit related to an injury.
- On July 2, 2007, Krupski's counsel sent a notice of claim to Costa Cruise Lines.
- The claims administrator for Costa Cruise Lines responded to the notice without indicating that it was the incorrect entity.
Procedural Posture:
- Wanda Krupski sued Costa Cruise Lines in the U.S. District Court for the Southern District of Florida three weeks before the one-year statute of limitations was set to expire.
- After the statute of limitations had run, Costa Cruise Lines filed court documents identifying Costa Crociere S. p. A. as the proper defendant.
- The District Court granted Krupski leave to amend her complaint to add Costa Crociere as a defendant.
- Costa Crociere moved to dismiss, arguing the amended complaint was untimely and did not relate back under Rule 15(c).
- The District Court granted the motion to dismiss, holding that Krupski's failure to name the correct party was not a 'mistake' because she should have known the proper defendant's identity from her passenger ticket.
- Krupski (appellant) appealed to the U.S. Court of Appeals for the Eleventh Circuit, which affirmed the dismissal, with Costa Crociere (appellee) prevailing.
- The U.S. Supreme Court granted Krupski's petition for a writ of certiorari.
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Issue:
Does an amended pleading that changes a defendant fail to relate back under Federal Rule of Civil Procedure 15(c)(1)(C)(ii) if the plaintiff knew or should have known of the proper defendant's existence before the statute of limitations expired?
Opinions:
Majority - Justice Sotomayor
No. An amended pleading that changes a defendant can relate back even if the plaintiff knew of the proper defendant's existence. The text of Rule 15(c)(1)(C)(ii) focuses on the prospective defendant's knowledge, asking whether that party knew or should have known that it would have been named as a defendant but for the plaintiff's mistake concerning the proper party's identity. A plaintiff can know of a party's existence but still be mistaken about that party's role or status in the underlying events. The focus is on whether the new party understood or should have understood that it escaped suit only because the plaintiff misunderstood a crucial fact, not on the plaintiff's state of mind or diligence. Here, Costa Crociere should have known from the complaint's description of the ship operator's actions that it was the intended defendant, especially given its close corporate relationship and similar name to the originally sued party, Costa Cruise Lines.
Concurring - Justice Scalia
Justice Scalia concurred in the judgment and joined the majority opinion except for its reliance on the Advisory Committee Notes. He argued that the text of the Rule is what controls its meaning, not the intentions of the committee that drafted it. The Advisory Committee's insights are useful only as scholarly commentary, not as an authoritative source of law.
Analysis:
This decision resolves a circuit split and clarifies the 'mistake' requirement of Rule 15(c), making it easier for plaintiffs to correct pleadings after the statute of limitations has run. By shifting the inquiry from the plaintiff's knowledge to the prospective defendant's reasonable understanding, the Court prioritizes resolving disputes on their merits over strict application of statutes of limitation. The ruling provides a more forgiving standard, particularly in cases involving complex or confusingly named corporate structures, where a plaintiff might sue the wrong but related entity. Future courts must now focus on whether the correct defendant had notice and should have realized it was the intended target of the lawsuit, regardless of what the plaintiff knew or how quickly they acted to amend.
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