Labrador v. Industrial Contractors' Supplies, Inc., 1:13-cv-13029

Labrador sued ICS after a 2010 injury allegedly caused by a broken Diamond Glitter Bit; complaint filed in state court in Sept. 2013 and removed to federal court.
Labrador amended his complaint in May 2014 to add 3M as successor to the bit manufacturer; the amendment was filed about eight months after the statute of limitations expired for adding a new defendant.
The Amended Complaint duplicated the original counts (negligence, warranty, product liability, willful/gross negligence) and added identical counts against 3M.
3M moved to dismiss the claims against it as time-barred, arguing relation-back did not apply and claiming prejudice and lack of notice.
Labrador relied on Massachusetts Rule of Civil Procedure 15(c) and related precedent to argue the amendment relates back because the claims arise from the same occurrence and he promptly moved to amend after learning 3M’s identity.
The court denied 3M’s motion, concluding Massachusetts law permits the amendment to relate back, Labrador acted promptly and made an honest mistake in naming the defendant, and 3M failed to show prejudice or lack of entitlement to amendment.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether amended pleading adding 3M after limitations period relates back	Labrador: Mass. R. Civ. P. 15(c) allows relation back because claims arise from same conduct/occurrence	3M: Relation back inapplicable; amendment time-barred	Held: Relates back under Massachusetts Rule 15(c); amendment allowed
Whether Labrador made a permissible "mistake" (vs. mere lack of knowledge) when naming initial defendant	Labrador: He reasonably believed ICS was the manufacturer; discovered 3M’s role March 2014 and promptly amended	3M: Plaintiff only lacked knowledge, so amendment shouldn't relate back	Held: Massachusetts rule allows amendment to enable plaintiff to bring the suit he originally intended; prompt amendment and honest error suffice
Whether 3M was prejudiced by the delay such that amendment should be denied	Labrador: No prejudice identified by 3M; prompt amendment; general delay insufficient	3M: Would be prejudiced defending years after the incident	Held: 3M failed to demonstrate specific prejudice (lost evidence/witnesses); denial of leave not warranted
Whether actual or constructive notice to 3M during limitations period is required for relation back	Labrador: Notice not required under Massachusetts law; Mulrenin permits adding defendants without notice	3M: Lacked requisite notice that it might be added	Held: Notice is not a prerequisite under Massachusetts Rule 15(c); relation back allowed regardless of notice

Trans‑Spec Truck Svc., Inc. v. Caterpillar Inc., 524 F.3d 315 (1st Cir.) (statute‑of‑limitations dismissal appropriate when defense clear from pleadings)
Coons v. Industrial Knife Co., 620 F.3d 38 (1st Cir.) (state relation‑back rules can displace federal Rule 15(c))
Morel v. DaimlerChrysler AG, 565 F.3d 20 (1st Cir.) (one‑way ratchet: less restrictive state relation‑back rules govern)
Pessotti v. Eagle Mfg. Co., 946 F.2d 974 (1st Cir.) (under Massachusetts law an allowed amendment automatically relates back)
Marshall v. Mulrenin, 508 F.2d 39 (1st Cir.) (Massachusetts allows adding defendants even without notice; liberal substitution doctrine)
Castellucci v. U.S. Fid. & Guar. Co., 372 Mass. 288 (Mass.) (amendment policy is liberal but leave may be denied to protect prejudiced parties)
Berman v. Linnane, 434 Mass. 301 (Mass.) (factors for allowing substitution: honest mistake, prompt joinder, necessity to avoid injustice, prejudice to nonmoving party)