In the case of Schiavone et al. v. Fortune, also known as Time, Inc., in 1985, the U.S. Supreme Court ruled on a libel suit brought by four individuals against Time magazine for publishing an article that allegedly defamed them by linking them to organized crime and a murder investigation. The plaintiffs claimed that they were not aware of the defamation until after the one-year statute of limitations had expired under New Jersey law where they filed their lawsuit but within two years from publication which was allowed under federal law. The primary issue before the court was whether or not "discovery rule" applied - meaning if time limit should start when harm is discovered rather than when it occurs. The Supreme Court held in favor of Time Magazine ruling that discovery rule did not apply to mass media publications and thus upheld New Jersey's one-year statute limitation period starting from date of publication regardless if plaintiff knew about it or not at that time. This decision emphasized importance given to First Amendment rights over potential reputational harms while highlighting need for timely litigation in defamation cases involving mass media outlets.

In the dissenting opinion for Schiavone et al. v. Fortune, AKA Time, Inc., Justice Brennan argued that the majority's interpretation of Rule 15(c) was too narrow and restrictive. He believed that this rule should be interpreted to allow a plaintiff to correct a mistake in identifying the proper defendant within a certain time frame after filing their initial complaint, even if it is outside of the statute of limitations period. This would only apply if it could be shown that there was no prejudice against the new defendant due to delay or lack of notice about potential legal action against them. In his view, this approach better aligns with Rule 15(c)'s purpose - promoting decisions on merits rather than technicalities - and respects Congress' intent when they amended this rule in 1966.