Monday, January 9, 2023

Federal Court Finds that Relation Back Doctrine Does Not Save Party From Statute of Limitations Argument

In the case of Coleman v. W. Oilfields Supply Co., No. 4:21-CV-00090 (M.D. Pa. Dec. 6, 2022 Brann, J.), the court addressed statute of limitations issues in a trip and fall matter.

In this case, the Plaintiff attempted to secure leave to amend the Complaint to add another Defendant who was allegedly responsible for the condition that allegedly caused the Plaintiff’s trip and fall. That Defendant moved to dismiss the matter filed against it as being barred by the statute of limitations.
Chief Judge Matthew W. Brann 
M.D. Pa.

In response, the Plaintiffs argued that their claims against that new Defendant related back to the claims noted in the original timely filed Complaint.

Judge Brann granted the Motion to Dismiss and agreed with the new Defendant that the Plaintiffs could not rely upon the relation-back doctrine where there was no evidence that the Defendant in question had notice of the action within a 120 days of the date that the action was filed. Nor was there any evidence that the new Defendants should have known that the action would have been filed against it but for a mistake in identity.

The court otherwise found that the new Defendant was not so closely related to the original parties that had been given notice of the action such that notice of the lawsuit could be imputed to the new Defendant through the filing of the original Complaint against the original Defendants.

Anyone wishing to review a copy of this decision may click this LINK.

Source: “Digest of Recent Opinions.” Pennsylvania Law Weekly (Dec. 22, 2022).

Source of top image:  Photo by Altem Maltsev on

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