Also known as: relation back amendment · relation-back amendments · relation back amendments · relation back · Rule 15(c)
Written by attorneys · grounded in primary & secondary sources — see below
A procedural doctrine under which an amended pleading is treated as filed on the date of the original pleading when the law supplying the statute of limitations permits relation back.
Renata Russo sued Apex Brokerage for unauthorized trading in her account. After the limitations period expired she moved to add a fraud claim based on the same trades. The forum state's law allows relation back for such amendments. The court therefore treats the new claim as timely filed on the date of the original complaint.
Alexander sued River Jet for whistleblower retaliation arising from his termination. After the limitations period expired he moved to add a wrongful-termination claim against Urban Orbit, River Jet's wholly owned subsidiary that handled the same employment actions. State law treats the closely affiliated entities as a single employer for limitations purposes and imputes notice through shared counsel. The amendment therefore relates back.
Select any source to read its text and confirm it supports the definition.
The amendment relates back when the law that supplies the applicable statute of limitations permits relation back. State law therefore controls the analysis for state-law claims. If the state permits the new claim to be treated as filed on the date of the original complaint the federal court honors that rule.
Supporting sources
No. The key inquiry is what the party to be added knew or should have known within the Rule 4(m) period. The plaintiff's own knowledge or diligence is not the focus.
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Shared registered agents, overlapping officers, common addresses, and service that reaches the proper party through affiliated entities can show the added defendant received timely notice. State law then determines whether those facts permit relation back.
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No. When both claims arise from identical conduct and the same operative facts state law often permits relation back even if the new claim requires proof of a separate duty. The controlling question is whether the state treats the claims as interchangeable for limitations purposes.
Supporting sources
…the plaintiff knew or should have known of the proper defendant before filing her original complaint. The court also held that relation back was not appropriate because the plaintiff had unduly delayed in seeking to amend. We hold that relation back under Rule 15(c)(1)(C) depends on what the party to be added knew or should have…