Facts of Krupski v. Costa Crociere S.p.A.
On February 21, 2007, Wanda Krupski sustained an injury while on board a cruise ship operated by Costa Crociere S.p.A. Her cruise ticket included important contractual terms. The front of the ticket displayed the name “Costa Cruises” and provided the address of Costa Cruise Lines in Florida. However, the back of the ticket identified Costa Crociere S.p.A. as the carrier and included stipulations governing the filing of injury claims—among them, a one-year statute of limitations and the designation of a particular court for filing legal actions.
Believing Costa Cruise Lines to be the entity responsible for the operation of the ship, Krupski filed a negligence lawsuit against Costa Cruise on February 1, 2008. This was just under three weeks before the one-year statute of limitations expired.
After the statute of limitations had passed, Costa Cruise informed Krupski multiple times—through various legal filings and communications—that Costa Crociere was the proper defendant. Costa Cruise eventually moved for summary judgment on the basis that it was not the correct party to be sued. Krupski cross-moved for leave to amend her complaint to name Costa Crociere.
The district court granted the motion to amend, and Krupski filed an amended complaint on July 11, 2008, naming Costa Crociere S.p.A. as the defendant. By stipulation, Costa Cruise was dismissed from the lawsuit. Costa Crociere then moved to dismiss the amended complaint, arguing that the claim was time-barred because the amendment did not relate back to the date of the original complaint. The district court agreed and dismissed the case.
The Eleventh Circuit affirmed the district court’s dismissal, concluding that Krupski knew or should have known the identity of the correct defendant before the statute of limitations expired and that her delay in amending meant the requirements for relation back under Rule 15(c) were not satisfied.
Krupski appealed to the Supreme Court of the United States.
Issue
Whether, under Federal Rule of Civil Procedure 15(c), an amended complaint that changes the defendant relates back to the date of the original complaint when the plaintiff knew or should have known the identity of the proper defendant before the statute of limitations expired.
Rule of Law
Under Rule 15(c) of the Federal Rules of Civil Procedure, an amendment changing the party or the naming of the party against whom a claim is asserted relates back to the date of the original pleading if:
- The claim in the amended pleading arises out of the same conduct, transaction, or occurrence set forth in the original pleading;
- The party to be brought in by amendment received notice of the action within the period provided by Rule 4(m) so that it will not be prejudiced in defending on the merits; and
- The party knew or should have known that the action would have been brought against it, but for a mistake concerning the proper party’s identity.
The focus is on what the newly added party knew or should have known—not on the plaintiff’s knowledge or diligence in seeking to amend.
Reasoning in Krupski v. Costa Crociere S.p.A.
The Supreme Court emphasized that the core question under Rule 15(c) is whether the newly added defendant knew or should have known that it would have been named in the original lawsuit but for the plaintiff’s mistake regarding its identity.
In Krupski v. Costa Crociere S.p.A., the Court noted that the original complaint made it clear that Krupski intended to sue the entity responsible for operating the cruise ship. Although she named Costa Cruise, the actual operator was Costa Crociere. The Court rejected the notion that a plaintiff’s awareness of a party’s existence automatically negates the possibility of a “mistake” within the meaning of Rule 15(c). A plaintiff might know of a party’s existence yet misunderstand that party’s role or relationship to the events giving rise to the claim.
The Court further explained that Rule 15(c) does not list the plaintiff’s diligence as a condition for relation back. Unlike certain other procedural rules that allow courts to consider equitable factors or the plaintiff’s conduct, Rule 15(c) contains specific criteria that focus on the knowledge of the newly named party.
The Court found that Costa Crociere had reason to know that it was the intended defendant, given the nature of the complaint and its close relationship to Costa Cruise. Costa Crociere should have realized that the failure to name it was due to a misunderstanding, not a deliberate choice to exclude it from the litigation.
Krupski v. Costa Crociere S.p.A. Judgment
Yes. The amended complaint related back to the date of the original filing under Rule 15(c) because Costa Crociere knew or should have known that it would have been named as the defendant but for Krupski’s mistake concerning its identity.
The Supreme Court reversed the judgment of the Eleventh Circuit Court of Appeals and remanded the case for further proceedings.
Conclusion
The Supreme Court’s decision in Krupski v. Costa Crociere S.p.A. underscores that the relation back doctrine under Rule 15(c) is meant to ensure fairness and accuracy in litigation. The plaintiff’s awareness or diligence is not determinative; instead, the focus is on the new defendant’s awareness that it was the intended party. In reversing the Eleventh Circuit, the Court reaffirmed that procedural rules should not become traps for plaintiffs when the correct defendant had timely notice and understood the nature of the claim.