Federal Rules of Civil Procedure

Krupski v. Costa Crociere

Issues 

Whether a plaintiff, who has imputed knowledge of the identity of a defendant, files an amended complaint to add the known defendant after a  one-year statute of limitations, can “relate back” to the filing date of the original complaint through the application of Federal Rule of Civil Procedure 15(c)?

 

Wanda Krupski (“Krupski”) suffered an injury as a passenger on a cruise ship owned and operated by Costa Crociere S.p.A. (“Costa Crociere”). In the United States District Court of the Southern District of Florida, her lawyer filed suit against Costa Cruise, N.V., LLC, Costa Crociere’s booking agent. The parties dismissed that suit by stipulation, because the owner and operator of a cruise ship is subject to liability, not the booking agent. Krupski filed an amended complaint against Costa Crociere—the correct party. Costa Crociere filed a motion to dismiss. The district court granted the motion, finding that Krupski had not made a “mistake” within the meaning of Federal Rule of Civil Procedure 15(c) (“Rule 15(c)”) that would allow the amendment to relate back to the original filing of the complaint. The Eleventh Circuit affirmed. The Supreme Court’s decision will clarify what constitutes a “mistake” within the meaning of Rule 15(c).

Questions as Framed for the Court by the Parties 

Fed. R. Civ. P. 15(c)(l)(C) Permits An Amended Complaint To "Relate Back", For Limitation Purposes, When The Amendment Corrects A, "Mistake Concerning The Proper Party's Identity". Other Circuit Courts of Appeal Construe The Rule As Applying To Substitution Of The Correct Defendant For A Related Corporation With A Similar Name. The Eleventh Circuit Has Concluded That There Can Be No Such "Mistake" Where The Plaintiff Had Imputed Knowledge Of The Identity Of The Added Defendant Prior To Filing Suit. Does The Eleventh Circuit Construction Of Rule 15(c)(l)(C) Undermine The Purpose Of The Rule And Is It Inconsistent With The Decisions In Other Circuits?

Wanda Krupski used a South Carolina-based travel agent to purchase a cruise from Costa Cruise Lines, N.V., LLC (“Costa Cruise”) in Hollywood, Florida. Krupski v. Costa Crociere, 330 Fed.Appx. 892, 893 (11th Cir.

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Additional Resources 

·      Wex: Law about Civil Procedure

·      Wex: Law about Complaint

·      Wex: Law about Pleading

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Jones v. Michigan Dept. of Corrections

Issues 

Does the Prison Litigation Reform Act (PLRA), which requires that prisoners first exhaust all available administrative remedies prior to filing a civil rights suit in federal court, mandates that a prisoner's entire civil suit be dismissed from federal court if the prisoner has failed to totally exhaust all available administrative remedies for each claim prior to filing suit? Additionally, does a prisoner, who proceeds to file suit in federal court but fails to attach to his complaint proof and documentation of how he exhausted all available administrative remedies, must have his entire case dismissed from  federal  court? Finally, does a prisoner's entire civil rights case must be dismissed from  federal  court if, during the process of exhausting available administrative remedies, he failed to specifically name the parties whom he later named as defendants in his federal court case?

 

Lorenzo Jones and Timothy Williams both filed suit against the Michigan Department of Corrections on the grounds that the treatment they received in jail violated their Constitutional civil rights. The Circuit Court held that neither plaintiff fulfilled their requirements to totally exhaust available administrative remedies under 42. U.S.C. § 1997e of the PLRA. The Circuit Court held that Jones failed the exhaustion requirement because he failed to either describe or attach proof of how he exhausted administrative remedies in his complaint. See Jones v. Bock, 135 Fed at 839. Although Williams did attach proof of exhaustion to his complaint, the Circuit Court held that he still failed the PLRA’s exhaustion requirement because he did not specifically name the defendant in his initial grievance filings with prison officials. See Williams v. Overton, 136 Fed at 862. In these consolidated cases, Petitioners argue that the Circuit Court's holdings amount to judicially-created pleading requirements that are inconsistent with the PLRA’s text, the Federal Rules of Civil Procedure, and judicial norms. Respondents maintain that the PLRA instituted a “new regime” for inmate Civil Rights Act suits and that the text and structure of the PLRA require the Circuit Court’s heightened pleading requirements. See Brief for Respondents at 27-28. How the Supreme Court decides these condensed cases will reflect its view of the correct balance of burden between inmate plaintiffs and the judiciary. These cases will either require prisoners to be more vigilant in asserting their own civil rights or require the judiciary to be more active in defending prisoners’ rights.

Questions as Framed for the Court by the Parties 

Jones v. Michigan Dept. of Corrections:

1. Whether satisfaction of the PLRA’s exhaustion requirement is a prerequisite to a prisoner's federal civil rights suit such that the prisoner must allege in his complaint how he exhausted his administrative remedies (or attach proof of exhaustion to the complaint), or instead, whether non-exhaustion is an affirmative defense that must be pleaded and proven by the defense.

2. Whether the PLRA prescribes a “total exhaustion” rule that requires a federal district court to dismiss a prisoner's federal civil rights complaint for failure to exhaust administrative remedies whenever there is a single unexhausted claim, despite the presence of other exhausted claims.

Williams v. Overton:

1. Whether the PLRA requires a prisoner to name a particular defendant in his or her administrative grievance in order to exhaust his or her administrative remedies as to that defendant and to preserve his or her right to sue them.

2. Whether the PLRA prescribes a “total exhaustion” rule that requires a federal district court to dismiss a prisoner's federal civil rights complaint for failure to exhaust administrative remedies whenever there is a single unexhausted claim, despite the presence of other exhausted claims.

Purpose and Effect of the PLRA

If a prisoner feels that his civil rights have been violated during his incarceration, he has a right to file a civil rights claim in federal court. Each year, thousands of prisoners commence actions on these grounds. The Prison Litigation Reform Act of 1995 (“PLRA”), which was passed by Congress in 1996, was designed in response to an influx of prisoner civil rights litigation.

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Personal Jurisdiction

Overview

Personal jurisdiction refers to the power that a court has to make a decision regarding the party being sued in a case. Before a court can exercise power over a party, the U.S. Constitution requires that the party has certain minimum contacts with the forum in which the court sits.  International Shoe v Washington, 326 US 310 (1945).

Taxonomy upgrade extras: 

Deposition

Overview

A deposition is a witness's sworn out-of-court testimony. It is used to gather information as part of the discovery process and, in limited circumstances, may be used at trial. The witness being deposed is called the "deponent."

Civil Procedure

Overview

Broadly speaking, civil procedure consists of the rules by which courts conduct civil trials.

Res judicata

Definition

Res judicata translates to "a matter judged." 

Overview

Generally, res judicata is the principle that a cause of action may not be relitigated once it has been judged on the merits. "Finality" is the term which refers to when a court renders a final judgment on the merits.

Res judicata is also frequently referred to as "claim preclusion," and the two are used interchangeably throughout this article. 

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