Worthington v. Wilson
8 F.3d 1253 (1993)
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Rule of Law:
Under Federal Rule of Civil Procedure 15(c), an amended complaint that substitutes named individuals for previously designated "unknown" defendants does not relate back to the original filing date because a plaintiff's lack of knowledge of a defendant's identity is not a "mistake concerning the identity of the proper party."
Facts:
- On February 25, 1989, Richard Worthington was arrested by a police officer from the Peoria Heights Police Department.
- Worthington advised the arresting officer that he had a pre-existing injury to his left hand.
- In response, the arresting officer allegedly grabbed and twisted Worthington’s injured hand.
- A second police officer arrived, and the two officers wrestled Worthington to the ground and handcuffed him.
- The officers then hoisted Worthington from the ground by his handcuffs, which allegedly caused him to suffer broken bones in his left hand.
- For the next two years, Worthington did not know the specific names of the officers involved in his arrest.
Procedural Posture:
- On February 25, 1991, Richard Worthington filed a complaint in the Circuit Court of Peoria County, Illinois (state trial court) against the Village of Peoria Heights and 'three unknown named police officers.'
- The Village of Peoria Heights removed the action to the U.S. District Court for the Central District of Illinois (federal trial court).
- Worthington voluntarily dismissed his claims against the Village and was granted leave by the district court to file an amended complaint.
- Worthington filed an amended complaint, substituting police officers Dave Wilson and Jeff Wall for the 'unknown' officers.
- Defendants Wilson and Wall filed a motion to dismiss the amended complaint, arguing it was barred by the statute of limitations and did not relate back under Rule 15(c).
- A magistrate judge recommended that the motion to dismiss be granted.
- The U.S. District Court judge adopted the magistrate's recommendation and granted the motion to dismiss.
- Worthington (appellant) appealed the district court's dismissal to the U.S. Court of Appeals for the Seventh Circuit.
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Issue:
Does an amended complaint, which substitutes named police officers for previously designated "unknown named police officers," relate back to the date of the original complaint under Federal Rule of Civil Procedure 15(c) when the plaintiff's failure to name the officers was due to a lack of knowledge of their identities, not a mistake?
Opinions:
Majority - Manion
No. An amended complaint that substitutes named defendants for previously 'unknown' defendants does not relate back under Rule 15(c) because the plaintiff's failure to name the defendants in the original complaint was due to a lack of knowledge, not a 'mistake' concerning their identities. The court reasoned that both the pre- and post-1991 amendment versions of Rule 15(c) require that the new party knew or should have known that 'but for a mistake concerning the identity of the proper party,' the action would have been brought against them. Citing its precedent in Wood v. Worachek, the court emphasized the distinction between a 'mistake' (such as a misnomer or misidentification) and a 'lack of knowledge.' Rule 15(c) allows relation back to correct a mistake, but not to add a party whom the plaintiff simply did not know about when filing the original suit. Since Worthington's complaint named 'unknown police officers' due to his inability to identify them before the statute of limitations ran, this was a lack of knowledge, and the amendment was therefore time-barred.
Analysis:
This decision solidifies a strict interpretation of the 'mistake' requirement in Rule 15(c) within the Seventh Circuit, creating a significant hurdle for plaintiffs, particularly in civil rights cases where defendants' identities may not be immediately known. By distinguishing a lack of knowledge from a legal 'mistake,' the court places the burden squarely on plaintiffs to conduct diligent investigations to identify all proper parties before the statute of limitations expires. This ruling clarifies that the 1991 amendment to Rule 15(c), which relaxed notice requirements, did not alter the fundamental principle that ignorance of a defendant’s identity does not justify relation back.
