Worthington v. Wilson
1992 U.S. Dist. LEXIS 6067, 1992 WL 85124, 790 F. Supp. 829 (1992)
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Rule of Law:
Federal Rule of Civil Procedure 15(c) permits relation back of an amended complaint changing a party's name only if the amendment corrects a "mistake" concerning identity, which, under Seventh Circuit precedent, does not include initially naming "unknown" defendants due to a lack of knowledge, and federal procedural rules prevail over conflicting state relation-back doctrines in federal question cases.
Facts:
- Richard Worthington was arrested on February 25, 1989, by two police officers in the Peoria Heights Police Department.
- Worthington advised the arresting officer that his left hand was injured at the time of the arrest.
- The officer grabbed and twisted Worthington’s injured hand and wrist.
- Worthington responded by shoving the officer away.
- A second officer arrived, and the two officers wrestled Worthington to the ground and handcuffed him.
- The officers then hoisted Worthington from the ground by the handcuffs, which caused him to suffer broken bones in his left hand.
Procedural Posture:
- On February 25, 1991, Worthington filed a complaint in the Circuit Court of Peoria County against the Village of Peoria Heights and "three unknown named police officers," alleging constitutional rights violations under 42 U.S.C. § 1983.
- The Village of Peoria Heights removed the action to the United States District Court for the Central District of Illinois and moved to dismiss the claims against it.
- Worthington voluntarily dismissed the counts against the Village before a hearing on the Village's motion to dismiss.
- On June 17, 1991, Worthington filed an amended complaint in federal court, naming Dave Wilson and Jeff Wall as defendants.
- Wilson and Wall moved to dismiss the amended complaint, asserting the statute of limitations had run and that it failed to state a proper claim under § 1983.
- On December 19, 1991, Magistrate Judge Robert J. Kauffman issued a recommendation that both the motion to dismiss and a pending motion for sanctions (filed earlier by the Village) be allowed.
- Worthington filed an objection to the Magistrate's recommendation.
- On March 17, 1992, the District Court held an additional hearing on the pending motions.
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Issue:
Does an amended complaint naming previously "unknown" police officers relate back to the original filing date under Federal Rule of Civil Procedure 15(c) when the plaintiff initially lacked knowledge of their identities, and does state law govern relation back in § 1983 actions where a federal rule on the matter exists?
Opinions:
Majority - Mihm, Chief Judge
No, the amended complaint naming previously "unknown" police officers does not relate back to the original filing date under Federal Rule of Civil Procedure 15(c) because replacing "unknown" parties with actual names due to an initial lack of knowledge does not constitute a "mistake" as interpreted by the Seventh Circuit. Furthermore, federal law (Rule 15(c)) governs relation back, not state procedural rules. The court first addressed the 1991 amendment to Rule 15(c), which changed the notice requirement from Schiavone v. Fortune, allowing notice within the 120-day period for service under Rule 4(j) instead of before the statute of limitations expires. The court found this amended rule applicable as it was "just and practicable" and noted that the defendants conceded they received notice within this 120-day period. However, the court then turned to the "mistake" requirement of Rule 15(c). Citing Seventh Circuit precedents such as Wood v. Worachek and Rylewicz v. Beaton Services, Ltd., the court found that substituting actual names for fictitious "unknown" parties due to a plaintiff's initial lack of knowledge does not qualify as correcting a "mistake" under Rule 15(c). While acknowledging its respectful disagreement with this interpretation, arguing that the focus of Rule 15(c) should be on notice to the defendant rather than the plaintiff's state of mind, the court felt bound by the controlling Seventh Circuit authority. Finally, the court rejected Worthington's argument that Illinois state law (§ 2-413) should govern the relation-back issue. Citing Lewellen v. Morley, the court stated that federal courts only absorb state rules (like tolling or extension rules) when federal law neglects the topic. Since Federal Rule 15(c) directly addresses relation back, federal law controls, and when federal and state rules clash, federal law prevails. Thus, the amended complaint naming Wilson and Wall could not relate back, and the two-year statute of limitations for the § 1983 claim had expired.
Analysis:
This case provides a critical interpretation of Federal Rule of Civil Procedure 15(c), particularly concerning the "mistake" requirement for relation back when a plaintiff initially designates defendants as "unknown" or "John Doe." It firmly establishes that, at least in the Seventh Circuit, a plaintiff's lack of knowledge about a defendant's identity is not a "mistake" in the eyes of Rule 15(c), even with the rule's more liberal notice provisions. This creates a significant hurdle for plaintiffs who cannot identify specific individuals at the time of filing, reinforcing the importance of diligent pre-filing investigation. The decision also reiterates the principle that federal rules of procedure govern in federal question cases, overriding conflicting state procedural rules, even when state statutes of limitation are borrowed for federal causes of action like § 1983 claims.
