Krupski v. Costa Crociere, S.p.A. (2009)
- Docket
- 09-337
- Decided
- 2009-01-01
Summary
Question: Does the Eleventh Circuit's construction of Federal Rule of Civil Procedure 15(c)(1)(C), which permits an amended complaint to relate back when the amendment corrects a "mistake concerning the proper party's identity," undermine the purpose of the rule? Conclusion: Yes. The Supreme Court reversed the Eleventh Circuit, holding that relating back under Rule 15(c)(1)(C) depends on what the party to be added knew or should have known, not on the amending party's knowledge or timeliness in seeking to amend the pleading. With Justice Sonia Sotamayor writing for the majority, the Court reasoned that the text of Rule 15 asks what the prospective defendant "knew or should have known", not what the plaintiff "knew or should have known" as determined by the Eleventh Circuit. Here, the Court further reasoned that Cost Crociere should have known that Ms. Krupski's failure to name it as a defendant was due to a mistake concerning the proper party's identity. Thus, Ms. Krupski should be allowed to add Costa Crociere in her complaint. Justice Antonin Scalia wrote separately, concurring in part and concurring in the judgment. He noted that he did not support the majority's use of the Notes of the Advisory Committee to the Federal Rules of Civil Procedure in reaching its decision.