Scott v. Village of Spring Valley, 577 F. App'x 81

Scott sued the County of Rockland, Village of Spring Valley, and the Village police department under 42 U.S.C. § 1983.
Scott sought to amend to add Officers Joseph Brown and Oscar Lopez as named defendants.
The district court denied leave to amend, holding the amendment did not relate back under Rule 15(c)(1).
The issue centers on whether the new officers can be added after the statute of limitations via relation back.
The court analyzes Rule 15(c)(1) criteria and constructive notice doctrines to determine timeliness.
The Second Circuit affirmed, holding the proposed amendment did not relate back and thus was untimely.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Does the amendment relate back under Rule 15(c)(1)(C)?	Scott argues relation back applies since conduct arises from original pleading.	Defendants contend no relation back because criteria unmet within 120 days and no identity mishap.	No relation back; amendment untimely.
Can constructive notice by same counsel justify relation back?	Constructive notice imputes knowledge to officers because counsel represents them.	No constructive notice; no prior notice to officers and no implied knowledge from complaint.	Constructive notice not established.
Is the failure to name officers within statute an excusable mistake under Rule 15(c)?	Desires to treat as a mistake of identity allowing relation back.	Failure to identify individual defendants when plaintiff knows they must be named is not a mistake.	Not an excusable mistake; relation back not allowed.

Hogan v. Fischer, 738 F.3d 509 (2d Cir. 2013) (relating to when failure to name individuals is not a mistake for relation back)
Gleason v. McBride, 869 F.2d 688 (2d Cir. 1989) (constructive notice where same attorney represents new defendants)
Krupski v. Costa Crociere S. P. A., 560 U.S. 538 (U.S. 2010) (claim relates back when plaintiff misunderstands which entity is responsible)