Jacobsen v. Osborne

Primarily at issue is whether, pursuant to Fed. R. Civ. P. 15(c)(3), a proposed amendment to a complaint to add new parties relates back to the date of the original complaint, especially for replacing "John Doe" defendants, thereby defeating a limitations bar as to those putative parties. For his action seeking relief under, inter alia, 42 U.S.C. § 1983, Michael Jacobsen appeals the denial of his motion to amend in order to substitute the correct defendants (police officers and sheriffs deputies) for an erroneously named officer and a "John Doe" deputy. We AFFIRM as to the deputies; REVERSE as to the officers; and REMAND.