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McKnight v. Iceberg Enters. LLC - No. 9:10-cv-03248-DCN, 2012 U.S. Dist. LEXIS 87816 (D.S.C. June 26, 2012)


In Goodman v. Praxair, the Fourth Circuit stated that "naming Doe defendants self-evidently is no 'mistake' such that the Doe substitute has received proper notice."


Doline L. McKnight filed a complaint in state court for negligence/recklessness, strict liability, and breach of implied warranty of merchantability and/or fitness for a particular purpose against defendants Mid-Continent Office Distributors, LP and Mid-Continent Office Distributors, Inc. The case was removed to federal court based on diversity jurisdiction. McKnight alleged that while working as an employee of Wal-Mart and on her lunch break, she sat down in a chair in the break room and the chair leg gave out, causing serious injuries. She further alleged that Mid-Continent "designed, constructed, manufactured, assembled, tested, inspected, marketed, sold, distributed, placed, reconstructed, maintained, and refurbished the chair." Defendants filed a motion to dismiss for negligence/recklessness and strict liability based on the expiration of the statute of limitations.


Should the Court grant the motion to dismiss?




The court  denied the motion to dismiss. It held that because the relation back requirements of Rule 15(c)(1)(C) were satisfied, the court found that McKnight's claims for negligence/recklessness and strict liability against Mid-Continent related back to the date of the original complaint. As such, Mid-Continent's motion to dismiss based on the expiration of the statute of limitations failed. The Court further added that Mid-Continent should have known that, as the chair manufacturer, it would be included in McKnight's complaint. When an added party "has been given fair notice of a claim within the limitations period and will suffer no improper prejudice in defending it, the liberal amendment policies of the Federal Rules favor relation back."

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