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Massachusetts Court Discusses Relation Back Rule for Amended Pleadings

In a civil lawsuit, the complaint sets forth the plaintiff’s claims against the defendant, and if the allegations in the complaint are not properly pleaded, the complaint may be dismissed. Thankfully, Massachusetts’s liberal standards typically allow a plaintiff to file an amended complaint even if the initial complaint was dismissed. A plaintiff who wishes to pursue a claim following a dismissal of the complaint must comply with the statutory requirements, however, including the statute of limitations, or his or her claim may be barred in its entirety. Recently, the United States District Court for the District of Massachusetts analyzed whether a plaintiff is barred from pursuing claims if the statute of limitations runs after the initial complaint is dismissed but before the amended complaint is filed, in a case in which the plaintiff alleged he was harmed in the workplace. If you suffered a work injury, it is advisable to speak with a Massachusetts personal injury attorney regarding your potential causes of action.

Factual and Procedural Background of the Case

It is reported that in January 2016, the plaintiff was injured in an industrial accident while at work. He filed a workers’ compensation claim following the accident and received a settlement. In January 2019, the plaintiff filed a lawsuit in the Massachusetts courts alleging negligence claims against the defendant corporation that owned the facility where the accident took place and the container that exploded, causing him harm, and other entities that distributed the container. The defendants removed the case to federal court and filed motions to dismiss, arguing lack of personal jurisdiction and failure to state a claim.

It is alleged that in July 2019, the court granted the defendants’ motions, dismissing the plaintiff’s complaint without prejudice and allowing him thirty days to file an amended complaint. The plaintiff filed an amended complaint later that month, after which the defendants filed motions to dismiss, arguing that the amended complaint was barred by the statute of limitations. In opposition, the plaintiff argued that the amended complaint was timely under the relation-back theory.

Relation Back Under Massachusetts Law

In Massachusetts, a negligence claim must be filed within three years of the date of harm. Thus, the plaintiff’s original complaint was timely. The court stated that both state and federal law allow for a subsequent pleading to relate back to an original pleading, although the standards vary under each law. Specifically, state law broadly permits an amended pleading to relate back to the original complaint while federal law allows an amended pleading to relate back only if the amended pleading sets forth claims that arose out of the same transaction or conduct as set forth in the original pleading.

In the subject case, the court found that under either the state or federal standard, the plaintiff’s amended complaint related back to the date of his original complaint and was not barred by the statute of limitations. Specifically, the court held that the amended complaint arose from the same occurrence as the original complaint. Thus, the court denied the defendants’ motions to dismiss.

Speak with a Dedicated Personal Injury Attorney

If you suffered harm in an accident, it is in your best interest to speak with a dedicated Massachusetts personal injury attorney regarding what damages you may be able to recover from the party responsible for your injuries. The diligent attorneys of Karsner & Meehan will advocate tirelessly on your behalf to help you pursue the full amount of compensation you may be owed. We can be contacted at 508-822-6600 or via the form online to schedule a meeting.