Daniels v. The Carter-Jones Lumber Company, 1:17-cv-00982

On April 11, 2014, Clara Daniels was injured while inspecting windows delivered to Carter-Jones Lumber; plaintiffs sued for negligence and loss of consortium.
Plaintiffs (West Virginia domiciliaries) filed an initial complaint on April 10, 2017 naming EnerLux, Carter-Jones, and “John Doe, Owner of Transport Company” (one day before Maryland’s 3-year negligence statute of limitations expired).
Plaintiffs sought and obtained leave to amend, and filed an Amended Complaint on August 31, 2017 substituting J.B. Hunt Transport, Inc. for the John Doe; J.B. Hunt was served on September 1, 2017.
J.B. Hunt moved to dismiss under Rule 12(b)(6) as time-barred because the amendment occurred after the limitations period and, in the court’s view, did not relate back under Fed. R. Civ. P. 15(c).
The central legal question was whether the Amended Complaint related back to the original filing date under Rule 15(c)(1)(C), i.e., whether J.B. Hunt received timely notice and "knew or should have known" it would have been sued but for a mistake identifying the proper party.
The court concluded the Amended Complaint did not relate back and granted J.B. Hunt’s motion to dismiss as barred by Maryland’s three-year statute of limitations.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether amendment substituting J.B. Hunt for a John Doe relates back under Fed. R. Civ. P. 15(c)(1)(C) so the claim is timely	The John Doe designation was merely descriptive; plaintiffs lacked knowledge and thus made a "mistake"; J.B. Hunt had notice (present at incident) and shared counsel with EnerLux so would not be prejudiced	Naming John Doe is not a "mistake" under Rule 15(c); J.B. Hunt lacked notice within Rule 4(m) period and did not know or should not have known it would have been sued but for a mistake	Relation back denied: naming John Doe does not satisfy Rule 15(c)(1)(C)(ii) here; no evidence J.B. Hunt knew or should have known it would have been sued before limitations expired; claims against J.B. Hunt are time-barred

Bell Atl. Corp. v. Twombly, 550 U.S. 544 (2007) (pleading must state a claim plausible on its face)
Ashcroft v. Iqbal, 556 U.S. 662 (2009) (Twombly standard applies to all civil actions)
Krupski v. Costa Crociere S.p.A., 560 U.S. 538 (2010) (relation-back inquiry focuses on what the prospective defendant knew or should have known during the Rule 4(m) period)
Goodman v. Praxair, Inc., 494 F.3d 458 (4th Cir. 2007) (naming Doe defendants typically is not a "mistake" that permits relation back)
Locklear v. Bergman & Beving AB, 457 F.3d 363 (4th Cir. 2006) (distinguishing lack-of-knowledge mistakes from misnomers; substitution for John Doe usually fails Rule 15(c))
Barnes v. Prince George’s County, 214 F.R.D. 379 (D. Md. 2003) (naming John Doe does not constitute the requisite mistake for relation back)