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Schiavone v. Fortune

477 U.S. 21 (1986)

JurisdictionUnited States

CourtSupreme Court of the United States

Year1986

StatusBinding authority

Summary

Pre-amendment relation-back timing themes for party changes; historical backdrop to modern 15(c)/4(m) structure

Pre-amendment relation-back timing themes for party changes; historical backdrop to modern 15(c)/4(m) structure

Civil Procedure — FRCP 15 amendments

Rule 15(c)(1)(C) “mistake” inquiry focuses on what the prospective defendant knew or should have known, not on the plaintiff’s diligence

Mayle v. Felix 545 U.S. 644 (2005)

“Conduct, transaction, or occurrence” construed in habeas amendments — often cited by analogy (use carefully in ordinary civil cases)

Due-process limits on adding a party and imposing judgment without opportunity to respond — amendment and party-addition caution

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