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Singletary v. Pennsylvania Department of Corrections

United States Court of Appeals for the 3rd Circuit
266 F.3d 186 (3d Cir. 2001)


Facts

Singletary (plaintiff) sued the Pennsylvania Department of Corrections (PADOC), the State Correctional Institute at Rockview (SCI-Rockview), SCI-Rockview’s superintendent, and “unknown corrections officers” (collectively, the defendants) after Singletary’s son committed suicide while he was a prisoner at PADOC. After the statute of limitations had run, Singletary moved to amend her complaint by adding a psychologist named Regan as a defendant. The district court held that Singletary’s amended complaint did not meet the conditions for “relation back” under FRCP 15(c)(3) and denied Singletary’s motion to amend and add Regan as a defendant. The district court granted summary judgment for all of the named defendants. Singletary appealed the grant of summary judgment for SCI-Rockview’s superintendent, Mazurkiewicz. The appellate court affirmed the district court’s grant of summary judgment for Mazurkiewicz and the district court’s denying Singletary’s motion to amend, finding that Singletary’s amended complaint did not meet the required conditions for “relation back”

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