Schwaninger v. Hyundai Motor Company, 3:15-cv-00858

Plaintiff Janet Schwaninger, administrator of Elizabeth Schaaf’s estate, sued over Schaaf’s death in an August 6, 2013 rollover; Schaaf was a front-seat passenger in a 2007 Hyundai Accent.
Schwaninger alleges the front passenger airbag system (installed in the Accent) was defective, causing door-latch unlocking, failure to restrain Schaaf, ejection, and death; she brings strict products liability and negligence claims.
Original complaint filed August 4, 2015 named Hyundai Motor Company and other Hyundai entities and the Key defendants (airbag suppliers) but did not name Hyundai Mobis; a First Amended Complaint adding Hyundai Mobis was filed August 10, 2015 (after the two-year Illinois limitations period).
Hyundai Mobis moved to dismiss under Rule 12(b)(6), arguing the claims against it are time-barred and, alternatively, that the pleading fails to state a claim.
The record showed Hyundai Mobis and its subsidiaries participated in early case negotiations, the subsidiaries were served and later dismissed without prejudice, and Hyundai Mobis waived service—evidence the company had notice during the Rule 4(m) period.
The court denied dismissal: it held the amendment adding Hyundai Mobis related back under Rule 15(c) and Krupski, and found the First Amended Complaint met federal notice-pleading requirements as to the airbag defect allegations.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Relation back under Rule 15(c) / statute of limitations	Amended complaint relates back to original complaint because it arises from same occurrence and Mobis had notice; Mobis should have been known to be a proper party	Mobis contends plaintiff made no mistake as to proper party, Key defendants are unrelated, so amendment does not satisfy Rule 15(c)(1)(C)(ii) and is untimely	Denied dismissal on statute of limitations grounds; amendment relates back because Mobis had notice and should have known it would have been sued but for a mistake (Krupski analysis)
Sufficiency of pleading (Rule 8/Iqbal-Twombly)	First Amended Complaint gives fair notice of claims against Mobis and alleges specific failures (door-latch unlocking, failure to restrain, ejection) sufficient for product-liability pleading	Allegations are conclusory, speculative, and too sketchy to put Mobis on notice	Denied dismissal for failure to state a claim; allegations are plausible and sufficient for notice pleading; facts can be developed in discovery

Erickson v. Pardus, 551 U.S. 89 (establishing deference to complaint allegations on Rule 12(b)(6) review)
Bell Atlantic Corp. v. Twombly, 550 U.S. 544 (pleading must state a plausible claim, not mere labels and conclusions)
Ashcroft v. Iqbal, 556 U.S. 662 (plausibility standard and context-specific assessment of pleadings)
Krupski v. Costa Crociere S.p.A., 560 U.S. 538 (Rule 15(c)(1)(C)(ii) focuses on what prospective defendant knew or should have known during service period)
Airborne Beepers & Video, Inc. v. AT&T Mobility LLC, 499 F.3d 663 (7th Cir.) (clarifying Rule 8 notice-pleading sufficiency in this circuit)