Supreme Court Rules 9-0 in Case of Mistaken Defendant
In a rare 9-0 decision, the U.S. Supreme Court ruled today that when a party mistakenly sues the incorrect party, they may still file their claim against the proper party. The court will consider the suit still filed in a timely manner if the party to be added knew or should have known about the lawsuit. The Court found that the Eleventh Circuit applied the wrong standard when it decided the case.
Wanda Krupski, the plaintiff in the case, was injured on a cruise. Her ticket was purchased from "Costa Cruise Lines, N.V.," which was a separate entity from the cruise line, "Costa Crociere S.p.A." The suit was filed only against Costa Cruise Lines as the sole defendant. Costa Cruise Lines waited for the statute of limitations to pass, then moved to dismiss the case, arguing that as the sales agent, it was not responsible for Krupski's injuries. Krupski sought to amend her complaint to name Costa Crociere.
The outcome of the case depended on a technical provision of the Federal Rules of Civil Procedure. The rule governs the effective dates of changes to a complaint. Specifically, when a party wishes to change their complaint to add a new party, they may be allowed to have the changes treated as if it they were filed on the same date as the original pleading. This is important in situations where a statute of limitations may make it impossible to successfully sue the proper party in a new lawsuit.
Justice Sotomayer delivered the opinion of the Court, which made clear that the focus should not be on whether the plaintiff knew who they should really sue, but whether the proper defendant knew that but for a mistake by the plaintiff, they would be a defendant in the lawsuit. The opinion stated:
"The Rule's text does not support the Eleventh Circuit's decision to rely on the plaintiff's knowledge in denying relation back. The question ... is not whether Krupski knew or should have known Costa Crociere's identity as the proper defendant, but whether Costa Crociere knew or should have known ... that it would have been named as the defendant but for an error."