No Relation Back: District Court Bars Substitution of John Doe Defendants After Statute of Limitations in § 1983 Opiate Withdrawal Death Case

The estate of an incarcerated decedent filed a complaint against the correctional facility, the warden of the facility and “John Doe” correctional officers on January 31, 2024. The complaint stemmed from the incarcerated decedent’s February 1, 2022, death due to complications associated with opiate withdrawal. The plaintiff’s claims included a § 1983 claim of deliberate indifference, alleging that the incarcerated decedent died based on his underlying drug withdrawal.

On June 4, 2025, the plaintiff filed an amended complaint, where they identified for the first time, correctional officers and supervisors as named defendants. As a result, the newly named defendants filed a motion to dismiss the amended complaint on the basis that the statute of limitations barred the plaintiff from substituting the John Doe defendants. The District Court agreed and dismissed the plaintiff’s amended complaint against the newly added correctional officers.

In granting motion to dismiss, the District Court held that the plaintiff’s claims were barred by Pennsylvania’s two-year statute of limitation. In objecting to the motion to dismiss, the plaintiff raised two arguments: (1) there was “good cause” to extend the relation-back period to encompass adding newly named defendants; and (2) that because the newly named defendants were supervisory defendants, they shared “identity of interest” with the original named defendants and could be added as defendants.

The court quickly dispelled the plaintiff’s argument that good cause existed to allow the substitution of John Doe defendants more than a year after the passing of the statute of limitations. The court found that the plaintiff did not make any effort to identify the newly added parties prior to filing the initial lawsuit. Additionally, the plaintiff exhausted the statute of limitations before even attempting to substitute the John Doe defendants.

The court also discredited plaintiff’s “relation back” argument, noting that in order for this doctrine to apply, there must be a showing that: (1) the claim set forth in the amended pleading arose out of the initial conduct/transaction alleged in the original complaint; (2) the parties received adequate notice of the institution of the proceedings; and (3) the parties sought to be added knew that they would be defendants in the lawsuit.

The court relied heavily on the fact that plaintiff did not demonstrate that the parties had actual or constructive notice of the suit within 90 days of the filing of the original complaint. The court delineated that constructive notice can be established where parties share an attorney or had “identity of interest.” Identity of interest generally means that the parties are so closely related in their business operations or other activities that the institution of an action against one serves to provide notice of the litigation of another. The court held that non-management employees do not share a sufficient nexus of interest with their employer to establish identity of interest. Additionally, the court considered the fact that the original defendants and the newly added defendants did not share the same attorneys so F.R.Civ.P. 15(c) did not trigger constructive notice.

Here, plaintiff failed to show that the parties were on notice of the institution of the original proceeding, or that the parties knew that they would be defendants in plaintiff’s litigation. Based on that, the court granted the defendants’ motion to dismiss.