Evelyn Farmer-Celey v. State Farm Ins. Co. & Mark Pray, 163 A.3d 761

On Jan. 1, 2009 appellant Evelyn Farmer‑Celey was injured in a rear‑end collision allegedly caused by Mark Pray; State Farm was Pray’s insurer.
Appellant (pro se, in forma pauperis) filed an initial complaint on Dec. 27, 2011 captioned "State Farm Ins. Co. for Mark Pray, et al." a few days before the limitations period expired.
State Farm moved to dismiss, arguing actions must be brought against the tortfeasor and that Pray was not named; the court granted leave to amend to clarify defendants.
Appellant filed an amended complaint (May 9, 2012) that explicitly listed Pray (c/o State Farm); initial service on Pray’s mother’s address failed, default was vacated, and Pray was later served in prison.
Pray moved for dismissal on statute‑of‑limitations grounds; the trial court granted summary judgment holding the amended complaint did not relate back because the original complaint did not name Pray.
The D.C. Court of Appeals reversed, concluding the original timely complaint sufficiently named Pray and thus no Rule 15(c) relation‑back inquiry was required; remanded for further proceedings.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the original complaint named Pray so that the amended complaint did not change the party	The original caption "State Farm Ins. Co. for Mark Pray, et al." and allegations show Pray was intended and named as a defendant	The caption only named State Farm (as agent) and Pray was not properly named or served during the limitations period	Held: The original complaint sufficiently named Pray; there was no change in party, so relation‑back under Rule 15(c) is not implicated and filing was timely
Whether insufficiency/timing of service bars the claim (preservation and analysis)	Service timing was a separate question and in any event trial court effected service because plaintiff was in forma pauperis	Pray argued lack of timely notice within limitations and challenged service at mother’s address to vacate default	Held: Insufficiency/timing of service was not preserved for appeal; the court need not decide timeliness of service now and remanded for further proceedings if appropriate

Young v. U‑Haul Co., 11 A.3d 247 (procedural standard for reviewing summary judgment)
Pritchett v. Stillwell, 604 A.2d 886 (liberal application of Rule 15(c) and two‑step relation‑back inquiry)
Varela v. Hi‑Lo Powered Stirrups, Inc., 424 A.2d 61 (filing tolls statute of limitations)
Baba v. Goldstein, 996 A.2d 799 (distinguishing timeliness of filing from timeliness of service; Rule 4(m)/Rule 41(b) considerations)