Ceara v. Deacon, 916 F.3d 208

Rafael Ceara, a pro se incarcerated plaintiff, sued under 42 U.S.C. § 1983 claiming a corrections officer assaulted him on Sept. 5, 2010.
In his timely original complaint Ceara identified the officer variously as “John Doe” and as “C.O. Deagan” (a misspelling), and included identifying facts (shift, location, that the officer had a brother at the facility, and that the officer was the younger brother).
The Attorney General’s Office later informed Ceara that Officers John Haag and Joseph Deacon were on duty at the relevant time and place.
After the statute of limitations expired, Ceara amended to replace “John Doe / C.O. Deagan” with “Officer Joseph Deacon.” Deacon moved for summary judgment arguing the amendment was time-barred.
The district court granted summary judgment, applying Barrow and treating the original filing as a John Doe complaint that could not relate back under Fed. R. Civ. P. 15(c)(1)(C).
The Second Circuit vacated and remanded, holding Ceara’s original pleading was a misnomer/misspelling of the correct defendant (not a true John Doe placeholder) and the amendment related back.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether an amendment that substitutes the correct name for a mis‑spelled defendant relates back under Fed. R. Civ. P. 15(c)(1)(C) so the claim is timely	Ceara: original complaint named the same individual (albeit misspelled) with identifying facts; amendment corrected a misspelling and should relate back	Deacon: the amendment came after the statute of limitations and should be treated as adding a new defendant (a John Doe situation) so no relation back under Barrow	The Second Circuit held the amendment related back: Ceara’s filing was a misnomer, not a John Doe placeholder; Barrow was misapplied and relation back is permitted

Barrow v. Wethersfield Police Department, 66 F.3d 466 (2d Cir. 1995) (held that replacing John Doe defendants does not relate back because lack of knowledge of names is not a "mistake of identity")
Krupski v. Costa Crociere S.p.A., 560 U.S. 538 (2010) (clarified that knowledge of a party’s existence does not preclude a mistake of identity for relation‑back analysis)
Hogan v. Fischer, 738 F.3d 509 (2d Cir. 2013) (applied Barrow’s framework for Rule 15(c)(1)(C) in § 1983 context)
Datskow v. Teledyne, Inc., 899 F.2d 1298 (2d Cir. 1990) (relation back allowed where plaintiff mislabelled the correct defendant)
Ingram v. Kumar, 585 F.2d 566 (2d Cir. 1978) (relation back permitted for minor misspelling of defendant’s name)