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Civil Rights Claim Against Patrolman Relates Back to Filing of Original Complaint

By FindLaw Staff on April 28, 2010 | Last updated on March 21, 2019

In Robinson v. Clipse, No. 08-6670, the Fourth Circuit faced a challenge to the district court's grant of defendant's motion for summary judgment in plaintiff's section 1983 suit against a highway patrolman, arising from his arrest and conviction for failing to stop for patrolman's blue light and for possession of a stolen vehicle. 

In reversing the judgment, the court held that the district court erred in granting the summary judgment to the patrolman based on running of the statute of limitations because Rule 15(c)'s requirements have been satisfied, the amendment naming the patrolman as defendant relates back to the date of the original complaint.

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