Summary
This Appellate Division, Second Department decision reverses a trial court order denying the plaintiff's motion for leave to amend a personal injury complaint to add a corporate defendant under the relation-back doctrine. Although the lower court relied on the law of the case doctrine following a prior statute-of-limitations dismissal, the appellate court exercised its discretion to evaluate the amendment's merits. Concluding that the omitted entity was united in interest with original defendants and received timely notice, the court granted the amendment, finding the initial failure to name the corporation stemmed from a mistake of law.
Topics
Practice areas
Questions Presented
- Whether the appellate court may grant leave to amend the complaint to add Quadrozzi Realty Corp. under the relation‑back doctrine despite the lower court’s law‑of‑the‑case determination that the claim was time‑barred.
Holdings
- The appellate court granted the plaintiff’s motion for leave to amend, finding the relation‑back doctrine satisfied the three prongs and that the law‑of‑the‑case doctrine does not bind an appellate court.
Key quotations
“The relation-back doctrine allows causes of action asserted against a new defendant in an amended complaint to relate back to causes of action previously asserted against a codefendant in the same action for statute of limitations purposes” (at *2)
“The linchpin of the relation-back doctrine is whether the new defendant had notice within the applicable limitations period” (at *3)
Factual background
In February 2014 the plaintiff slipped and fell on snow and ice on a property in Queens. He sued the property owners, including Quadrozzi entities, but omitted Quadrozzi Realty Corp. as a defendant. The omission was later argued to be a mistake of law.
Procedural history
The plaintiff filed a personal injury action in 2016. The defendants moved to dismiss for statute of limitations and lack of personal jurisdiction, which the trial court granted in June 2021. The plaintiff later moved to amend the complaint to add Quadrozzi Realty Corp. under the relation‑back doctrine; the trial court denied the motion in March 2023, holding the law‑of‑the‑case doctrine barred relitigation. The plaintiff appealed.