Doyle v. Frost

Summary

The Tennessee Supreme Court held that Tenn. R. Civ. P. 15.03 permits an amended complaint adding a governmental entity as a defendant to relate back to the date of the original, timely filed complaint. The court concluded that applying the relation-back doctrine does not extend the Tennessee Governmental Tort Liability Act's statute of limitations when the governmental entity received timely notice and the rule's other requirements are satisfied.

Holdings

1. Tennessee Rule of Civil Procedure 15.03 applies to governmental entities. An amendment adding a governmental entity relates back to the date of the original complaint when the Rule's requirements are satisfied.
2. The doctrine of sovereign immunity does not preclude application of Rule 15.03 when the party sought to be added by amendment is a governmental entity.

Questions Presented

1. Whether Tennessee Rule of Civil Procedure 15.03 permits an amendment adding a governmental entity as a defendant to relate back to the date of the original complaint.
2. Whether the Tennessee Governmental Tort Liability Act's one-year statute of limitations and sovereign-immunity provisions preclude application of Rule 15.03 to a governmental entity that received timely notice of the action.

Disposition

reversed_and_remanded