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Worthington v. Wilson

8 F.3d 1253 (1993)

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Worthington v. Wilson

United States Court of Appeals for the Seventh Circuit
8 F.3d 1253 (1993)

Facts

Richard Worthington (plaintiff) was arrested on February 25, 1989, by two officers of the Peoria Heights Police Department. The officers re-injured Worthington’s already injured hand, breaking several bones. On February 25, 1991, Worthington filed suit against the Village of Peoria Heights (the village) (defendant) and “unknown named police officers” under 42 U.S.C. § 1983, alleging that the officers’ conduct violated Worthington’s constitutional rights. The suit was filed on the last day of Illinois’s two-year statute-of-limitations period for a § 1983 claim. Worthington voluntarily dismissed his claim against the village but pursued his claim against the officers. On June 17, 1991, Worthington amended his complaint, naming officers Dave Wilson and Jeff Wall (defendants) in place of the previous “unknown named police officers.” Wilson and Wall moved to dismiss the amended complaint because it was filed after the statute of limitations expired. They argued that the amended complaint did not relate back to the original complaint under Federal Rule of Civil Procedure 15(c) and was therefore time-barred. The district court agreed and dismissed Worthington’s complaint. Worthington appealed.

Rule of Law

Issue

Holding and Reasoning (Manion, J.)

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