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Wanda Krupski v. Costa Crociere S. P. A.

• 2009 • 560 U.S. 538 • Roberts Court
In the case of Wanda Krupski v. Costa Crociere S.P.A., 2009, the U.S Supreme Court ruled in favor of plaintiff Wanda Krupski. The issue at hand was whether a mistake made by Krupski in her original complaint, where she named the wrong defendant (Costa Cruise instead of Costa Crociere), could be corrected after the statute of limitations had expired. The District Court and Eleventh Circuit both held that it could not be amended because they believed that Costa Crociere did not have sufficient...Open Case
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Chief Roberts Court
Term: 2009
Docket: 09-337
560 U.S. 538
130 S. Ct. 2485
177 L. Ed. 2d 48
2010 U.S. LEXIS 4567
Argued: Apr 21, 2010

Wanda Krupski v. Costa Crociere S. P. A.

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Opinion Summary
AI Abstract

In the case of Wanda Krupski v. Costa Crociere S.P.A., 2009, the U.S Supreme Court ruled in favor of plaintiff Wanda Krupski. The issue at hand was whether a mistake made by Krupski in her original complaint, where she named the wrong defendant (Costa Cruise instead of Costa Crociere), could be corrected after the statute of limitations had expired. The District Court and Eleventh Circuit both held that it could not be amended because they believed that Costa Crociere did not have sufficient notice within the period set by Federal Rule for Civil Procedure 15(c). However, upon appeal to Supreme Court, it was found that there was indeed enough information available to Costa Crociere about its potential role as a defendant before expiration of limitation period. Therefore, an amendment should relate back to date when claim against initial party (wrongly named) was filed under Rule 15(c)(1)(C). This ruling clarified how courts should apply this rule regarding amendments and relation back doctrine.

Dissent Summary
AI Abstract

In the dissenting opinion for Wanda Krupski v. Costa Crociere S.P.A., Justice Scalia, joined by Justices Thomas and Alito, argued that the majority's interpretation of Rule 15(c)(1)(C) was incorrect. They contended that it is not enough for a party to know or should have known about an action within the specified period; they must also be aware that they would have been named as defendants but for an error made in good faith by the plaintiff. The dissenters believed this requirement was necessary to prevent plaintiffs from manipulating proceedings through strategic delays or other tactics. They further criticized the majority’s decision because it effectively allows plaintiffs to add new parties after limitations periods expire without showing any mistake concerning their identities at all – something which contradicts both text and purpose of Rule 15(c). In conclusion, they felt this ruling could potentially undermine statute-of-limitations defenses and encourage tactical gamesmanship.

Opinion written by Justice SSotomayor
Decided: Jun 07, 2010
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Oral Transcript
Argued: Oct 05, 2026
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