Law School Case Brief
Singletary v. Pa. Dep't of Corr. - 266 F.3d 186 (3d Cir. 2001)
For purposes of relation back under Fed. R. Civ. P. 15(c)(3), identity of interest generally means that the parties are so closely related in their business operations or other activities that the institution of an action against one serves to provide notice of the litigation to the other.
Plaintiff Dorothy Singletary was the mother of Edward Singletary, a prisoner who committed suicide while incarcerated at defendant State Correctional Institute at Rockview ("Rockview"). Singletary filed a lawsuit in federal district against Rockview and defendants Pennsylvania Department of Corrections and the former Superintendent of Rockview, Joseph Mazurkiewicz. Her original complaint also included as defendants "Unknown Corrections Officers." Singletary alleged that defendants violated her son's civil rights under 42 U.S.C.S. § 1983. Defendants filed motions for summary judgment, which were granted, presumably on the ground the action was barred by the applicable statute of limitations. Singletary filed a motion to amend her complaint to add as a defendant Robert Regan, a psychologist at Rockview. The district court denied that motion because it concluded that the amended complaint would not meet the conditions required for relation back under Federal Rule of Civil Procedure 15(c)(3). Singletary appealed the orders granting Mazurkiewicz summary judgment and denying her motion to for leave to amend.
Did the amended complaint meet the notice requirements of Rule 15(c)(3)(A)?
The appellate court affirmed the district court's orders. The court noted that the only chance for Singletary to prevail depended on her ability to succeed in: (1) amending her original complaint to add Regan as a defendant, and; (2) having the amended complaint relate back to her original complaint under Federal Rule of Civil Procedure 15(c)(3) so that she overcame the statute of limitations defense. The court ruled that the district court was correct in ruling that the amended complaint did not meet the notice requirements of Rule 15(c)(3)(A). Singletary could not avail herself of the "shared attorney" method of imputing notice to Regan because defendants' attorney was not assigned to the present case until after the relevant notice period under Rule 15(c)(3). Furthermore, the "identity of interest" method was not open to Singletary because Regan was not high enough in the administrative hierarchy of Rockview to share sufficient interests with any of the original defendants. Thus, the proposed amended complaint did not relate back to the original complaint.
As to Mazurkiewicz, the court ruled that there was no merit to Singletary's challenge because there was no evidence that Mazurkiewicz exhibited deliberate indifference to the decedent's medical needs.
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