Butler v. NCRC

An Appellant's original complaint must sufficiently identify all of the proper defendants in order for a later time-barred complaint to relate back under Federal Rule of Civil Procedure 15(c)(1).

Plaintiff Butler moves to appeal the lower court’s decision in favor of the defendants. Butler filed a complaint in federal district court against the National Community Renaissance Corporation that alleged her Fourth Amendment rights were violated when a search was conducted in her public housing home without a warrant. She later amended the complaint and added the Housing Authority of Los Angeles (HACoLA) as a defendant. The lower court dismissed the complaint with the reasoning that it was unclear whom Butler intended to sue. Later, Butler amended an additional complaint and added in her statement of facts that she intended to sue the Sheriff Department, the management company, the housing authority, as well as the city of Palmdale. This complaint was also dismissed on the same grounds as previously stated. Butler amended a third complaint naming the same defendants as well as the police officers who searched her home without the warrant. The defendants filed a motion to dismiss that was granted by the district court. The district court reasoned that “the original complaint did not sufficiently identify either HACoLA [or the police officers] as defendants.” The court also determined that the claims against the later added defendants “did not relate back, under Federal Rule of Civil Procedure 15(c)(1), to the time Butler filed her original complaint.” The panel concluded that the district court did not err when it determined that the complaint did not relate back to when Butler filed her initial complaint. The plaintiff did not make a mistake when naming the defendants in her original claim and did not establish that the defendants knew or should have known that she planned to file a lawsuit against them. Although the final complaint named showed the defendants Butler intended to sue, it was time-barred. AFFIRMED.