Worthington v. Wilson

790 F. Supp. 829 (1992)

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Worthington v. Wilson

United States District Court for the Central District of Illinois
790 F. Supp. 829 (1992)

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Facts

Richard Worthington (plaintiff) was arrested on February 25, 1989, by two officers of the Peoria Heights Police Department. During the arrest, the officers re-injured Worthington’s already injured hand, breaking several bones. Two years later, on February 25, 1991, Worthington filed suit against the Village of Peoria Heights (village) (defendant) as well as the “unknown named police officers” who injured him. The suit, which was brought under 42 U.S.C. § 1983, alleged violations of Worthington’s constitutional rights. It was filed on the last day of the statute-of-limitations period for a § 1983 claim under Illinois law. Just under four months later, on June 17, 1991, Worthington amended his complaint, naming officers Dave Wilson and Jeff Wall (defendants) as defendants in place of the “unknown named police officers.” The amended complaint omitted any claim against the village. Wilson and Wall moved to dismiss the amended complaint. They argued that the requirements for relation back under Federal Rule of Civil Procedure 15(c) were not satisfied and, consequently, the amended complaint was barred by the statute of limitations.

Rule of Law

Issue

Holding and Reasoning (Mihm, C.J.)

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