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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)

Rule:

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."

Facts:

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.

Issue:

Should the Court grant the motion to dismiss?

Answer:

No

Conclusion:

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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